International Taxation

International Taxation

While many organizations place special emphasis on minimizing the local Israeli tax burden, more than a few fail to dedicate the same attention to reducing tax burdens with respect to their operations outside Israel, despite the fact that the total effective tax rate on these activities often exceeds the Israeli tax rate.

In the absence of careful planning, gains and income from operations outside Israel could be subject to considerable tax liabilities. The acceleration of these liabilities, and certain sanctions on part of the tax authorities in Israel and other jurisdictions, could put a damp on the economic feasibility of operations and investments outside of Israel.

The International Taxation Department offers tax consulting to those investors – both corporations and individuals – that are involved in business activities overseas. Our services focus on the development of a comprehensive tax strategy, including the review of the holding structure of such corporations and individuals in the light of local and international tax laws and tax treaties, with an eye at minimizing the overall tax burden.

Additionally, the Department provides tax consulting to Israeli resident individuals on relocation as well as to foreign residents working in Israel. The services of the Department also include transfer pricing consulting. International tax consulting services are provided in cooperation with the tax consultants in the BDO International Network, when relevant.


  • Review of holding structures of companies and individuals for the purpose of optimizing the tax planning with respect to international operations. The Department has extensive knowledge and experience with respect to worldwide tax laws (which are frequently amended) and the variety of tax benefits available in Israel and overseas.
  • Review of existing holding structures for the purpose of minimizing the tax burden of foreign entities operating in Israel, based on utilizing the tax benefits available under Israeli domestic laws. The review includes tax implications of the place of operation, the origin of income, and tax liability upon the distribution of profits.
  • Assistance to Israeli residents in filing tax returns overseas. Israeli residents operating overseas are frequently required to file tax returns with the tax authorities in their country of operation. The International Taxation Department has acquired substantial knowledge in this field, offering consulting, assistance and instruction to entities that are required to file such returns.
  • Assistance in the establishment of entities in Israel and overseas.
  • Ongoing consulting and guidance regarding international holding structures. The Department provides constant consulting on the execution of specific transactions, transfer pricing, restructurings, and the method and timing pertaining to dividend distributions. The Department also provides assistance in obtaining pre-rulings from tax authorities in Israel and overseas.
  • Consulting to Israeli resident individuals on relocation overseas, including the preparation of tax overviews examining the residence status of individuals for tax purposes and the date of discontinuance of their Israeli residence. Related services also include consulting to foreign residents working in Israel, new immigrants, returning residents, etc.



Eli Alice

Partner, Head of International Taxation Department
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