The Doron, Tikotzky, Amir, Mizrahi law firm has offices in Ramat Gan, Haifa and Romania. It is the largest tax firm in Israel, and combines tax, private and commercial law professionalism, including local and international business and services of all measures and sorts. Representing clients with tax, private and commercial disputes, offering them representation and litigation in a variety of courts.
The office, which includes approx. 35 lawyers, economists and accountants, was established by lawyers and accountants from the public sector who practiced Israeli and international tax, private and criminal law. Therefore, the firm includes four main departments:
The Commercial Tax Department – deals in tax consulting of private citizens and companies in Israel and abroad and litigation in court and representation to the various tax authorities in all matters.
The Criminal Tax Department – accompanies and represents Israelis with criminal tax disputes, whether in an open investigation or in courts. This department has also published the monumental book in the subject of criminal tax law, named "Tax Offences".
The Private and Commercial Department – deals in a variety of legal subject, including trades, commercial enterprises, entrepreneur foundation, private litigation, commercial disputes, bank disputes, work law, contracts, family law, torts and much more.
The Real Estate Department – deals with many real estate deals, both private and commercial. In a wide range, as elementary deals of home and commercial rent and as far as complex international deals including hundreds and thousands of commercial and private units, and much more.
Ramat Gan 12 Hachilazon st, (Crystal House)
Tel: 972-03-6127446, Fax: 972-03-6127449
Haifa 58 Hameginim Blvd
Tel: 972-04-8526693 Fax: 972-04-8555976
Question about the article ask here:
eli-doron@taxlawyers.co.il
Eli Doron, adv. – Yaron Tikotzky, adv. (c.p.a) eli-doron@taxlawyers.co.il
A company that was established outside of Israel and managed from outside her, as well, is a foreign company for tax purposes, exempt from all foreign derived income. However, as the Israeli legislature wished to prevent Israelis, who are subject to tax on foreign derived income, from using the foreign occupation company for tax avoidance, determined that such a company is subject to income tax for the special occupation that in trades in.
A “special occupation” is, among other definitions, defined as consultant (including the financial, personal, military, agricultural, technical, engineering, management, political, scientific, taxation, business and economical fields) and management (including managing files, investments and property, company and organization management in receivership, dismantling procedures and bankruptcy).
Therefore, a foreign occupation company is a company that consists of four accumulating conditions:
(1) The company has no more than 5 managers and administrators (as defined in the Israeli Tax Code); it is not a subsidiary and not a company with public interest. However, foreign companies that accumulate only conditions (2)-(4) will also be considered foreign occupation companies.
(2) At least 75% of the foreign occupation company is directly or indirectly held (as defined in article 88 of the Israeli Tax Code) by Israeli residents or citizens (as defined in article 3A of the Israeli Tax Code).
(3) Those holding 50% of the management in the company are occupied by the company for the special occupation that the company provides.
(4) The majority of income and revenue of the company in a given tax year are derived from the special occupation of the company.
These conditions, although well established both in legislation and in court rulings, should nevertheless be interpreted according to the law’s end, which is to fight tax avoidance.
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