Key Areas of Expertise
- Tax Litigation: Corporate and individual representation in income tax appeals, administrative appeals and motions, VAT appeals, and Supreme Court appeals.
- Transactions, Mergers & Acquisitions: Ongoing legal advice to corporations and shareholders regarding tax-based transaction planning.
- Corporate & Individual Consultation: Ongoing counsel regarding the required conduct for minimizing tax liability derived from investment and business transactions in Israel and abroad, including written opinions on various tax issues.
- Pre-Ruling: Tax Authority pre-rulings, including authorizations pertaining to employee option plan, international taxation, M&A’s, investments, share swap and more.
- Tax Benefits: Taxpayer consultation and representation regarding tax benefits and incentives in Israel.
- Tax Authority Representation: Taxpayer representation in various assessment proceedings, including filing of tax objections and taxpayer representation before the Tax Authority in assessment discussions.
- Family Wealth Management: Tax planning for individuals and families with accumulated wealth, for optimal tax liability and inter-generational asset transference.
- Israeli Citizens Abroad: Tax consultation for Israelis residing overseas, new immigrants to Israel and returning residents.
- Land Tax: Legal counsel regarding combination transactions, group purchasing, residential properties, appeal committee representation and more.
- VAT Tax: Ongoing consultation, legal opinions and representation before VAT authorities, district courts and the Israel Supreme Court, with regard to corporate, NGO and financial institution VAT liability.
The department is known for its attorney excellence, in-depth knowledge, original thinking process, professional dedication and partner experience. Together with strong working relations with tax authorities, these attributes constitute high-quality, superior legal service.
The department is led by Yaron Mehulal, an attorney with over three decades of experience in tax law, and Noa Lev Goldstein, an attorney and CPA with twenty years of tax experience, including over 12 years as senior position holder at Israel’s Tax Authority.
- Tax Planning: Unique tax planning throughout an Israeli bank holdings sale resulted in minimal tax liability for the seller.
- Income Tax Objection and Assessment Discussions: Representation of a large Israeli public company in negotiations with the Israel Tax Authority, with respect to a tax assessment issued by the ITA to the company, demanding a tax liability of approximately 1 Billion NIS. The objection filed by the department and negotiations with the ITA resulted in the ITA’s acceptance of the vast majority of our claims. The tax settlement reflected a reduction of almost all tax liability demanded.
- Corporate Tax Litigation: Representation of an Israeli company owned by a large multinational corporation, in an income tax appeal process against the Israel Tax Authority’s Large Enterprise Income Tax Assessment Office. The appeal focused on issues relating to international taxation and transfer pricing, and culminated with the signing of a satisfactory tax settlement.
- Tax Litigation for Individuals: Taxpayer representation in an income tax appeal (before the district court and the Supreme Court), which deliberated a precedential issue that focused on establishing an individual’s country of residence for tax purposes. The appeal focused on the possibility of “splitting the family unit” for tax purposes. In an extremely influential verdict, Israel’s Supreme Court ruled in favor of the department’s position, stating that an individual can be classified as a “foreign resident” for tax purposes, although his close family (wife and children) resides in Israel. The department also represented an individual client in an income tax appeal, which resulted in a court ruling that stated that a portion of the compensation paid for the sale of rights in a publicly traded corporation is to be attributed to the company founder’s personal good will, and is therefore subject to a reduced capital gain tax rate.
- VAT-Related Litigation: Representation of a private company in an appeal against the Tax Authority – VAT. The appeal focused on VAT liability regarding compensation received by the company with respect to an agreement infringement. In a precedential ruling, Israel’s Supreme Court ruled that the majority of the compensation does not fall under VAT liability.
- Representation before Appeal Committee, in Accordance with Land Tax Law: Representation of a large Israeli company before an appeal committee, in accordance with Land Tax Law, regarding an issue pertaining to several tax fields. The proceedings resulted in a settlement that led to a significant tax reduction (millions of NIS).
- Pre-Ruling: A precedential pre-ruling regarding a complex merger between two Israeli high-tech firms, within the scope of a cash and stock transaction.
- Tax Planning & Consultation: The firm provided legal counsel regarding the planning of a multi-company business merger. The merger was estimated at hundreds of millions of NIS, and the firm’s advice helped reduce tax liability to a minimum.
- The Encouragement of Capital Investments Law: The firm provides counsel to numerous companies regarding the Encouragement of Capital Investments Law, and handles related income tax appeals.
- Assessment Proceedings: Representation of numerous corporate and individual taxpayers in assessment proceedings before the Tax Authority, including early-process tax liability resolution.
- Residence Rulings: Representation of numerous corporate and individual taxpayers, in issues relating to their place of residence. Advise includes legal opinions and the obtainment of authorizations from the Tax Authority, when necessary.
- Import Tax & International Trade: The firm’s legal services encompass import tax and international trade.