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Pre-Ruling services

Tax position does not necessarily need to have risks. The Pre-Ruling institution, governed by the Israeli Income Tax Ordinance and the VAT law, is one way of eliminating the risks and enables the taxpayer achieving certainty regarding his tax positions on a said transaction.  

Request for a Pre-Ruling from the Tax Authorities can be filed on several issues as followed: 

  • Tax exempts Re-Structuring transactions (mergers, splits, spin-offs, associating assets to affiliate corporation); 
  • International taxation – establishing residency; tax treaty; Permanent Establishment issues, transfer pricing issues; taxation on foreign residents.  
  • Approval of beneficiary enterprise as described in the Law for Encouragement of Capital Investments.  
  • Taxation of financial institutions.  
  • Taxation of stock options plans for employees.  
  • In most of the exempts re-structuring transactions (especially mergers, split, spin-off) the approval of the Tax Authority is required.  

Crowe Horwath (Israel) has the expertise and experience to submit and obtain an approved Pre-Ruling. We will analyze the said transaction and its potential risks, and advice on the need for applying for Pre Ruling depending on the facts and circumstances.