David Sherman

July 2024: Improved Purchase Tax Benefit for New Immigrants 📈Those who repatriate to Israel and purchase a first residence will pay significantly lower purchase tax rates than the tax payable according to the current benefit. The Knesset Finance Committee has recently approved an amendment to purchase tax regulations in this regard. This change addresses the situation where benefits were only applicable to the purchase of second and subsequent apartments, leaving the initial purchase without privileges. Old System 🧾 New repatriates could receive a tax discount on real estate purchases if they bought an apartment within one year before repatriation or up to seven years after it. However, Israelis buying their first apartment were exempt from paying taxes on the purchase of housing costing up to 1.98 million shekels while repatriates had to pay a 0.5% tax. Thus, repatriates were at a disadvantage. New System 🛎️ Now, new repatriates buying their first apartment costing up to 1.98 million shekels will be exempt from paying taxes. When buying an apartment costing between 2 and 6.5 million shekels, they will only pay 0.5% of the amount exceeding 2 million. It is important to note that for those buying a new apartment during the construction phase, the construction period will not be considered as the period of benefit application, provided that no more than three years have passed from the date of purchasing the apartment until the repatriate's first entry to Israel. Also, the commission has equated the rights of repatriates purchasing an apartment as an investment with those of other buyers.

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In Cyprus, property-related taxes include VAT, property transfer tax, and stamp duty, each with its own specific regulations and rates. 1️⃣ New homes are subject to Value Added Tax (VAT) at a standard rate of 19%, and this tax is paid by the buyer. 2️⃣ The tax on property transfers differs according to the property's transaction value. The fees can vary from 3% to 8%, with more expensive properties usually drawing larger fees. 3️⃣ Stamp duty is typically paid by the buyer and is calculated based on the value of the property transaction. The rates for stamp duty can vary depending on the type of property and the transaction value. To learn more about regulations and taxation of real estate in Cyprus, visit REALTYon on July 3-4 👉 https://lnkd.in/ddU74fTz #realtyon #realtyonexpo #realtyonexpocyprus2024 #realestate #realestateindustry #realestateinvestor #realtor #propertyexpo #expo #cyprus #limassol #cyprusrealestate

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New Reporting Obligations for Trustees in Israel: What You Need to Know For trustees overseeing trusts with beneficiaries who are immigrants or returnees to Israel, a significant change is on the horizon. A recent amendment to the Israeli income tax ordinance has revoked the long-standing exemption from reporting obligations for this group, effective from 2026. 🔍 Under the previous regulation, trustees were not obliged to file any report or statement to the Israeli tax authority regarding trusts with beneficiaries who qualified for the 10-year tax benefits period upon becoming Israeli residents. 📝 However, the new amendment will require trustees to include comprehensive details about the ultimate beneficiaries and all relevant personnel (such as the Settlor, Beneficiaries, Trustee, and even the Protector) in the annual tax return, regardless of whether the trust was already entitled to the past benefits. 💡 Notably, even if the trustee is an Israeli resident overseeing foreign trusts without Israeli assets, they must still provide these details, despite the trusts not being subject to reporting and taxation in Israel. 🌐 Given the numerous trusts overseen by trustees from abroad and the growing use of the trust mechanism in Israel, it is strongly advised that trustees seek professional guidance to ensure compliance with the new reporting requirements. The amendment underscores Israel's commitment to meeting global standards for transparency and reporting among countries, particularly those set by the OECD's Global Forum. As trustees, it is crucial to stay informed and take proactive steps to adhere to these changes, safeguarding the interests of the trusts and their beneficiaries. Feel free to reach out if you need assistance navigating these new regulations or have any questions regarding trust reporting obligations in Israel. #TrustLaw #IsraeliTaxation #ReportingObligations #Trustees #GlobalStandards Dvir Saadia YETAX

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🚀 New article just published! If you’re dealing with delays in receiving your new apartment from a contractor, this is a must-read. It covers your legal rights and compensation under Israeli law, including Amendment 9 to the Sale Law (Apartments). Protect your investment and know what you’re entitled to. Read the article https://did.li/iLAIw #RealEstate #LegalAdvice #PropertyRights #Homebuyers #Compensation #DelayInDelivery #IsraelLaw #RealEstateLaw

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📢 Attention Israeli Companies Operating Internationally and Foreign Companies Operating in Israel: Join Our Webinar on the New STTR Tax Rules! 📢 With the ITA’s recent publication summarizing the OECD’s "Subject to Tax Rules" (STTR), we are happy to invite you to a short, informative webinar where we will discuss the key elements of these rules, their implementation, and the expected impact. 🗓️ Date: September 18th 🕒 Time: 14:00 📍 Location: Zoom - https://bit.ly/3XjehM5 During this session, our experts will cover: Which countries are in scope. How the STTR will be applied. Its interaction with the wider Pillar Two (Global Minimum Tax rules); and Considerations on how it might impact you and your business. Don't miss this opportunity to gain valuable insights and prepare your business for these upcoming changes. 🔗 For registration >>> https://bit.ly/3XjehM5 #Tax #STTR #OECD #Webinar #GlobalTax #BusinessImpact #Deloitte

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Moving out of Israel requires careful tax planning to avoid unintentionally retaining Israeli tax residency status. Our new article covers: • What "Center of Life" means for Israeli tax purposes • Why residency status matters for income tax obligations • Examples of situations that can inadvertently retain Israeli tax ties • Proactive steps to disconnecting Center of Life before departing Read our tips here: https://hubs.ly/Q02y_JMv0

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PRACTICAL GUIDE TO ESTABLISHING YOUR CENTER OF VITAL INTERESTS IN ISRAEL 🇮🇱 For individuals with foreign assets and income, Israel remains one of the most attractive tax havens among developed countries. ⏰ Important reminder: December 31, 2025 is the last day to qualify for full tax benefits under the Milchan Law. After this date: ✅ What remains: - 10-year tax exemption on foreign-source income ❗️ What changes: - Obligation to declare worldwide income - Additional requirements for foreign companies owned by new residents 🔴 Important: Tax authorities may challenge the tax resident status even for those who arrived before December 31, 2025, if they determine that the Center of Vital Interests (CVI) was not effectively transferred to Israel. In such cases, the new (limited) benefits will apply. 📋 Key factors for establishing and documenting your CVI in Israel: 1⃣ Basic Requirements ▫️ Long-term housing contract (1+ year) or property purchase ▫️ Utilities and municipal taxes (arnona) in your name ▫️ Israeli bank account ▫️ Israeli driver's license ▫️ National Insurance (Bituach Leumi) registration ▫️ Health insurance coverage 2⃣ Financial Integration ▫️ Transfer of main savings to local banks ▫️ Working with Israeli brokers ▫️ Local credit cards ▫️ Israeli employment contract ▫️ Business registration (if applicable) 3⃣ Social Integration ▫️ Hebrew studies in Ulpan ▫️ Professional organization membership ▫️ Children's enrollment in local schools 4⃣ Wrapping Up Foreign Affairs ▫️ Closing unnecessary foreign bank accounts ▫️ Resolving foreign property matters ▫️ Terminating foreign business relationships 🔺 Document all activities demonstrating your presence and engagement in Israel – these may be required during tax authority reviews. The more systematic your approach to CVI transfer, the easier it will be to confirm your tax resident status from your relocation date. #IsraelTax #TaxIsrael #NewImmigrants #Aliyah #IsraelBusiness #InternationalTax

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Our Partner, Vassilis Vizas, Tax and Legal Services Leader took the stage at the 𝟏𝟐𝐭𝐡 𝐓𝐡𝐞𝐬𝐬𝐚𝐥𝐨𝐧𝐢𝐤𝐢 𝐓𝐚𝐱 𝐅𝐨𝐫𝐮𝐦 titled: "𝐂𝐡𝐚𝐥𝐥𝐞𝐧𝐠𝐞𝐬 𝐟𝐨𝐫 𝐭𝐡𝐞 𝐌𝐨𝐝𝐞𝐫𝐧 𝐓𝐚𝐱 𝐅𝐮𝐧𝐜𝐭𝐢𝐨𝐧" along with George Bizetas, Nick Pappas and Thomas Paramythas. The panel discussion shed light on the tax and accounting-related challenges stemming from the use of digital tools and AI. The latest breakthroughs in AI technology provide enterprises and professionals with fascinating opportunities in forecasting, supply chain, automating procedures and mitigating various risks. With its capacity for ever-growing learning, AI can help Tax professionals with the refinement of big data and computing. However, AI is merely a tool in the hands of humans and their critical thinking. #TaxForum #PwCGreece #AI

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Intergenerational Wealth Transfer Planning: Have You Considered International Tax Aspects? Transferring assets from an Israeli resident to heirs living abroad presents complex tax challenges, as inherited assets may be subject to foreign tax systems and estate taxes outside Israel, potentially significantly reducing the wealth transferred to future generations. Such tax complications can be prevented through advance international tax planning and sophisticated tools for intelligent intergenerational wealth transfer. At our recent intergenerational wealth transfer conference for private clients, Adv. Leor Nouman, Partner and Head of Tax Department at our firm, presented strategic solutions for handling international tax issues in intergenerational wealth transfer. Among the solutions presented - customized trust structures that allow heirs control over the timing and manner of receiving assets while optimizing tax aspects. For proper and personalized preparation for intergenerational wealth transfer planning, you are invited to contact our experts at S. Horowitz & Co. https://lnkd.in/exqCAZ_t

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According to estimates, the state is expected to receive between $2.5 billion and $3.5 billion in taxes from the transaction, and Israeli shareholders will incur the tax liability. Adv. (CPA) Racheli Guz-Lavi, Managing Partner and Senior Tax Partner at our firm, explains: "The company’s development center is in Israel, but it is registered in the US and its head office is in New York. Therefore, foreign investors in the company, including foreign venture capital firms, will have no tax liability in Israel. Nevertheless, a large amount of tax will still be paid by the founders and the Israel-resident investors, and by Israeli employees who have received stock options".   Click here to read more >> https://lnkd.in/dGEsSaAU

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The Columbia Law Review's website has been taken offline following the publication of an article criticizing Israel. The article, which described Palestinians as living under a “brutally sophisticated structure of oppression” by Israel, did not go through the proper review process, according to the publication's board. The article in question was authored by Rabea Eghbariah, a doctoral candidate at Harvard University, who argued for a new legal concept called "Nakba" to more accurately describe the current conditions of Palestinians. "Nakba," which means "catastrophe" in Arabic, refers to the 1948 establishment of Israel. Eghbariah criticized the shutdown in a statement to CNN, saying, "The attempt to silence my legal scholarship on the Nakba by shutting down the entire Columbia Law Review website not only reflects a pervasive and anti-intellectual Palestine exception to academic freedom but also testifies to a culture of Nakba denialism." #InternationalJustice #HumanRights #OccupiedTerritories #IsraelPalestine #Accountability #FreePalestine #GazaUnderAttack #StoptheGenocide #BreaktheSilence #PalestinianLivesMatter #EndIsraeliApartheid #IsraelApartheidState #IsraeliWarCrimes #IsraelisTerroristState #InternationalCriminalCourt #UnitedNations #OIC #ICJ #UnitedStates #USIsrael #AllEyesonRafah #USSupportsGenocide #USCongress #ColumbiaUniversity #GlobalPeaceSummit

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🤔 What Is Tax Planning and Why Is It Important for Businesses? Tax planning is a strategic process aimed at minimizing a company’s tax obligations through legal methods. It helps ensure financial stability, reduce tax burdens, and mitigate tax-related risks. In Armenia, tax planning is particularly crucial for businesses of all sizes, as it allows them to effectively leverage the benefits of different tax regimes and maintain compliance with regulations. ❓ Why Do Businesses Need Tax Planning? Reducing Tax Burdens: For instance, the Simplified Taxation System (STS) in Armenia allows small businesses with an annual turnover of up to approximately AMD 115 million to pay only 5% of their turnover. This regime excludes corporate income tax and VAT, making it especially advantageous for small enterprises. Forecasting Tax Liabilities: Effective tax planning enables businesses to anticipate future tax expenses, avoiding unexpected financial difficulties. Ensuring Compliance: Proper tax planning helps businesses adhere to reporting requirements, thus avoiding penalties and preserving tax benefits. Enhancing Competitiveness: By reducing operational costs through tax optimization, businesses can reinvest the saved funds in growth initiatives such as technology adoption or marketing. Strategic tax planning not only minimizes taxes but also lays the foundation for sustainable business growth, strengthens reputation, and attracts investments. For professional guidance in optimizing your taxes in Armenia, ArmGate offers expert consulting services tailored to your needs. Learn more about tax planning in Armenia: https://lnkd.in/ejW24bKK

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🖋️ Simplifying Document Certification and Translations in Israel 🖋️ As lawyers in Israel, we provide a range of certification services that don’t always require a notary. Whether it’s verifying translations, certifying copies, or other document countersigning, the process is simpler and more cost-effective than many people expect. One thing clients appreciate? In some cases, verifications can even be handled via video call—adding a layer of convenience and saving a trip to the office. 💻✨ #DocumentCertification #LegalServices #IsraeliLaw #TranslatingDocuments #Countersigning #LegalAssistance #BusinessLaw #RealEstateLaw #Israel #TranslationServices Please consult with a qualified attorney for advice specific to your situation.

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A few days ago, the Israel Tax Authority issued an announcement regarding the application of the #STTR rules to Israeli companies, specifically those subject to the "Encouragement Law". In a nutshell, the STTR may apply in tax treaties between Israel and developing countries. The STTR allows these countries to withhold additional tax at source when a company resident in a developed country makes a payment of specific income to a related company resident in Israel. This is on top of the tax rate stipulated in the treaty, ensuring that after taking into account the corporate tax applicable to that income in Israel (as of 2024, 7.5% or 6%), the total tax rate reaches up to 9%. Attached is an unofficial translation of the Israel Tax Authority's announcement into English for convenience only. #Pillar2 #BEPS #Tax #TaxTreaties

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I was very excited to attend the international tax conference of EY in Israel last week. In the short session I had presented possible funding instruments for M&A transactions of Israeli target companies and also some updates on recent court ruling issued by the district court in the Bay Ventures case. In short, under current Israeli tax circulars, performing a share buyback by an Israeli company from its shareholders can lead to significant tax implications, resulting in double taxation of the same income. The two-phased approach outlined in circular 2/2018 of the ITO highlights these tax implications. The Bay Ventures case introduces advantages in using preferred shares as a funding instrument for acquiring Israeli companies, circumventing the double taxation issue seen with share buybacks. Preferred shares can be a valuable tool for funding acquisitions of Israeli companies without facing double taxation challenges. Another important feature of pref. shares funding is that it is a common legal instrument for funding, hence may reduce possible discussions on the classification of such instrument at the level of a potential investor. Careful planning and compliance with Israeli tax laws are crucial to optimize financial and tax outcomes in such transactions. For tailored tax advice, consulting with tax professionals well-versed in Israeli corporate tax law is recommended. We are here to assist in any way needed. Thanks you all for attending the international conference and thank you EY for the great opportunity. #EY #Internationaltax

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 We’re pleased to share an exclusive insight from Yariv Ben Dov, a global partner member of the TPA Global network. Featured in the latest Bloomberg Tax Transfer Pricing Forum, Yariv represents TPA and Israel with an in-depth look at contract manufacturing transactions within the Israeli tax landscape📄 In his article, Yariv addresses the unique complexities multinationals face with contract manufacturing in Israel, covering: • The high-risk factors identified by the Israeli Tax Authorities, especially for contract manufacturers involved in high-value technology and R&D • Proven strategies for maintaining compliant documentation to support transfer pricing positions • The impact of government grants and subsidies on transfer pricing and how businesses can navigate these considerations 📥 Download the full article here: https://lnkd.in/dxe9Sjfm to explore Yariv’s expert analysis and see how strategic tax insights can empower your business 📥 #TPAGlobal #TransferPricing #BloombergTax #ContractManufacturing #Israel #TaxCompliance #InternationalTax #TaxForum #Insights

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Partner Sonia Hamshaw and Senior Associate Marissa Christodoulidou recently wrote an article examining the new provisions and procedures introduced as a result of the amendments to the Cyprus Companies Law, which were voted in on 15 March 2024.   Read the full article here: https://lnkd.in/gXRk98xp   #Cyprus #Corporate #crossborderconversion #crossbordermerger #crossborderdivision

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We are pleased to share with you the July Tax Flash, the new newsletter from S. Horowitz & Co. As we do every month, we compile for you the main tax updates, including references to hot topics, events and conferences, articles, tips, and more. In this flash, we will focus on two topics: transfer pricing in international technology sale transactions, and the extension of the temporary order for receiving tax funds due to profit from the realization of decentralized means of payment. To read the full information in the July Tax Flash: https://lnkd.in/dSJ-7gMz Leor Nouman | Moti Saban

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Transfer pricing in Armenia: Explore the guide for key insights and updates. ENG🌐➡️https://lnkd.in/em88mSqR Contributing Editor: Amanda Pedvin Varma / Steptoe LLP #TransferPricing #Armenia #ConcernDialog #Lexology

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