International Tax

As tax authorities have grown increasingly assertive and information has become easier to transfer across jurisdictions, we have navigated the challenges of global markets with proven expertise. Whether we are dealing with a corporate merger, an intellectual property transfer, or any other international transaction, we assure that tax liabilities are minimized in even the most complex scenarios. We are proud of our success in optimizing cross-border investment structures for multinational corporations and securing favorable outcomes in international tax disputes.

Services

Cross-Border Tax Planning: For Israeli companies expanding abroad, foreign companies already operating within Israel, and foreign companies looking to establish a presence in Israel, we provide guidance on tax-efficient structures. Our solutions leverage differences in tax treatment across jurisdictions and harness Israel’s tax treaties and other benefits to minimize liabilities and optimize the company’s tax position. We also help individuals, especially high-net-worth individuals who move between countries, to manage their international tax liabilities. We advise on the implications of dual residency or change of residency, utilize tax treaties to avoid double taxation, and leverage treaty benefits for income, capital gains, and estate taxes.

Cross-Border M&As: We offer international tax services for transactions involving multinational corporations. We help to structure the transaction to minimize tax burdens for both buyer and seller while addressing international tax implications, especially if the transaction spans multiple jurisdictions.

Tax Treaty Analysis: Our reviews of applicable tax treaties will help you avoid double taxation and maximize treaty benefits. We will show you how to structure payments to minimize withholding tax on dividends, royalties, and interest charges across borders.

Permanent Establishment (PE) Management: We can help you evaluate and manage PE risks to avoid unexpected tax liabilities in foreign countries. We will support your PE position by providing a legal opinion or tax ruling. 

Transfer Pricing: For transactions between related entities across borders, our team will help you develop tax-efficient pricing strategies that balance tax savings with regulatory compliance. 

Controlled Foreign Corporation (CFC) and Foreign Personal Services Company: We advise taxpayers on Israel’s CFC rules and on the tax aspects of ownership in foreign personal service companies.

Global Mobility and Expatriate Tax Services: We recommend ways to structure expatriate assignments to optimize tax outcomes for both employer and employee.

Articles

Shares versus Asset Deal in the Context of Purchasing IP Rights Located in Israel
Taxation of Real Estate Investments in Israel
The Advantages of an Israeli Family Company

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