International Taxation

Determination of Residency, Severance of Residency and Relocation

We examine the residency of an individual or company, whether in Israel or abroad, and provide the specific solution to the customer via consultation or specific tax decisions. There is a fundamental difference between determining residency for an individual, and residency for a company. Individual residency is determined by two tests. The days test and the center of life test. Read more about single residency here.

When examining a company’s residency, we will implement two tests: the incorporation test and the control management test. Under the incorporation test, a company incorporated in Israel is Israeli. Under the control and management test, a company whose control and management from Israel, although registered in a foreign company, will also be considered Israeli according to Israeli domestic law. Read more about company residency here.

Our firm handles cases dealing with the determination of residency and severance of residency as well as cases where agreements with foreign tax authorities need to be involved. Our office has many connections all over the world so we can help avoid the double taxation  of our clients and can combine the severance of residency with the determination of residency in another country.

Planning and Establishing a Company Structure Abroad

International taxation requires professionalism and specific experience. Our firm is involved in planning the structure of companies for operations abroad, specifically, structures in complex portfolios that require the establishment of companies all over the world. The service includes an examination of the chain of companies appropriate to the customer’s needs to minimize tax liability in international operations, a recommendation on how to invest, guidelines regarding tax liability in foreign countries and the tax balance to be paid in Israel.

Using this framework, we also examine issues of management and control from Israel among other things. Nimrod Yaron lectures at various conferences on tax planning and the structure of companies as part of various professional lectures.

Assistance in establishing companies abroad: We assist in the registration of companies abroad and drafting registration documents in order to support their tax position. We also assist in opening bank accounts and cooperate with a wide range of colleagues and professional service providers abroad to provide you with excellent service. We have recently established firms worldwide, including firms in Singapore, Hong Kong, England, Malta, Ukraine, Brazil, Poland, Romania, BVI, and various other firms across the globe.

Taxation of Trusts

We aid in the establishment of trusts in Israel and abroad and in the examination of existing trusts (beneficiary of an Israeli resident, trust of a foreign resident, trust of nonresidents, etc.). We also aid in the determination of reporting liability and taxation examination. Furthermore, we create tax plans that include the use of a trust. 

Treatment of Withholding Tax on Remittances Abroad

We closely examine exceptions to withholding tax and obtain an exemption from withholding tax cases of payment from a resident of one country to a resident of another country. Furthermore, we aid in obtaining permits for a “special company” with the tax authority even in abnormal cases. In his position at the Tax Authority, Nimrod Yaron was responsible for handling financial transfers abroad. In this position, Nimrod gained a great deal of experience and was even involved in legislative proceedings surrounding the transfer of funds.

International taxation – Transferring Funds Abroad

Technical assistance is required when transferring funds, especially in light of the current bank requirements that make the transfers difficult. Accountant approvals and arranging tax payment is necessary. Our firm works with a currency service provider approved by the Ministry of Finance which saves up to 70% Technical analysis to maximize return. Read more about remittances from Israel to abroad here.

Transfer of funds to Israel

Our office provides technical assistance to firms in transferring funds to Israel in light of the stricter requirements of banks which make it difficult to transfer. We issue CPA approvals and arrange tax payments as needed.

Transfer pricing

Accompanying research on transfer prices and economic work on the subject, a relevant topic in any international transaction. We understand the value chain and create real-time documentation that will help future auditing. Our firm provides services in this field to companies of all types and sizes, from a company in their infancy to public corporations. Read more about transfer prices here.

Advice on Tax Treaties

The applicability of treaties and the way treaties are applied. Our firm has extensive experience in implementing tax treaties, even in cases where there are translation or drafting errors in the treaty. Read more about tax treaties here.

Counseling for New Immigrants and Returning Residents

New immigrants are entitled to an exemption from reporting income earned outside of Israel for ten years from the date of their immigration. Returning residents are also entitled to a tax exemption of up to ten years for all of their income earned outside Israel, depending on the duration of their time abroad before returning.

Our firm accompanies new immigrants and returning residents in order to highlight their rights in front of the tax authority and assist in proper tax planning that will reduce the overall tax liability, both in Israel and in their country of origin. Read about the tax benefits for a new immigrant and a returning resident here.