Client Update | The Rise and Fall of the New Israeli Deemed Distribution Rules to Non-Israeli Affiliates

In our client update of 23 November, 2017 (see here), we informed you about the new Israeli deemed distribution rules, which are set out under the newly enacted Section 3(i1) of the Israeli Income Tax Ordinance (the “Ordinance”). Under these rules, a loan from an Israeli company, which is granted to its 10 percent or more shareholder or affiliate and that is outstanding at the end of the year following the year in which it was granted, may be viewed as giving rise to a taxable distribution. To read the full client update – click here.