Legal Opinions
Tax decisions often hinge on legal interpretation, and since Israeli tax law is a fast-evolving mix of statutes, case law, regulations, and administrative guidelines, much remains open for uncertainty and dispute. A well-reasoned legal opinion can provide clarity and reduce risk.
By delivering legal opinions that are technically rigorous and practical, STL offers you decisive tools for planning and negotiation. We analyze the law, weigh competing interpretations, and craft positions that stand up to the scrutiny of tax authorities, counterparties, and courts, even when our interpretation differs from that of the Israel Tax Authority. We believe in our opinions, which reflect decades of experience and know-how.
Our Experience
We have delivered legal opinions on a wide range of complex tax issues. The following list is just a sample.
§ The application of Section 62A of the Israeli Income Tax Ordinance to so-called “wallet companies” (personal service companies), including the release of assets under temporary relief provisions
§ The application of Section 9(2) of the Israeli Income Tax Ordinance to institutional investors, with an analysis of available tax exemptions across different types of investments
§ Income characterization, addressing whether specific receipts qualify as dividends, management fees, active business income, or passive income, with implications for tax liability and reporting
§ International tax issues, such as the commencement or termination of Israeli tax residency; the taxation of mixed-source income, in which part is derived in Israel and part is derived abroad; and the question of whether a foreign corporation’s activities constitute a permanent establishment (PE) in Israel
§ Employee equity compensation, including the calculation of the capital component upon exercise of options granted by publicly traded companies
§ The characterization of real estate gains as either capital gains or business income, an issue with significant implications for applicable tax rates, reporting obligations, and potential exposure to VAT
§ Withholding tax obligations in financing and international transactions
§ The classification of a company as a real estate association (igud mekarkein), with implications for taxation of share transfers, withholding obligations, and overall structuring of real estate investments
§ The eligibility of specific services for zero-rated VAT under the various provisions of Israel’s VAT Law
