Tax
Herzog Fox & Neeman has the strongest Tax practice of any law firm in Israel. The Tax practice is preeminent due to the scope of its work, its expertise in international tax planning, and its influence on Israel’s tax regime.
Herzog Fox & Neeman’s tax lawyers have long been involved in structuring major international transactions, as well as obtaining landmark tax rulings that have shaped Israel’s Hi-Tech and venture capital industry.
The tax practice is comprised of six specialized areas:
- Corporate Tax - Tax Aspects of M&A and Capital Markets Transactions and Current Corporate Tax Advice - The Tax department has been involved in the tax aspects of most of the transactions handled by the firm, as well as in the tax planning for many of the multinational corporations operating in Israel. The department’s lawyers create and implement sophisticated structures to optimize the global tax efficiency of the firm’s clients
- Private Clients, Trusts, and Estates – The Private Clients, Trusts, and Estates group is located within the Tax department and provides unparalleled service to high net worth individuals. The group regularly handles complex cross-border tax and estate planning to optimize families’ goals regarding global tax efficiency.
- Investment Funds / Private Equity - Since the infancy of the investment funds industry in Israel, Herzog Fox & Neeman has led the way in the growth of the venture capital, private equity fund, and hedge fund industries in Israel. The Investment Funds / Private Equity group represents numerous domestic and international investment funds with a variety of fields of activities
- International Tax Planning – The International Tax Planning group helps to coordinate and direct clients’ worldwide tax affairs - including strategies to minimize exposure to foreign corporate taxation, permanent establishment exposure, withholding taxes, European VAT and similar taxes and duties, and many exposures unique to particular jurisdictions.
- Transfer Pricing – Our transfer pricing department offers Israel’s most comprehensive guidance on international transfer pricing, with a full range of services, focusing on the legal, economic, and business-related aspects of the client's tax structure and supply chain. Our team prepares the required transfer pricing studies, in accordance with Israeli and foreign regulations (including the newly adopted OECD BEPS regulations), intercompany agreements, transfer pricing policies, APAs, transfer pricing valuations, and the BEPS readiness process.
- Employee Tax Benefits - The Employee Tax Benefits group is one of the few specialized groups in Israel and is the market leader. The group provides advice to public and private start-up companies, newly formed companies, multinationals, and subsidiaries on all aspects of employee equity benefits plans and employment agreements.
Tax News & Insights
Dear friends, clients and colleagues, On July 19, 2021, the Israeli Government published for public comments a memorandum for the

A Revolution in the Taxation of Partnerships and Joint Investments in Israel Publication of a Law Memorandum – Taxation of Partnerships
Dear friends, clients and colleagues, The OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (the IF) issued a statement

The OECD Reaches Agreement on the Two-Pillar Solution
Dear Clients, Colleagues and Friends, On May 31, 2021, Israel and the United Arab Emirates (“UAE”) signed their first-ever bilateral

Client Update – Israel and the UAE Sign Tax Treaty
WeWork has changed its operating model in Israel to a franchise. Herzog represented WeWork in the transaction to transfer all of

Herzog represented WeWork in the transaction to transfer all of its assets and operations in Israel to AMPA group
WeWork has changed its operating model in Israel to a franchise. Herzog represented WeWork in the transaction to transfer all of

Our Client WeWork has changed its operating model in Israel to a franchise
Congratulations to our Japanese client SUNCORPORATION for the fantastic $2.4 billion transaction of its Israeli subsidiary Cellebrite. Under the transaction

Congratulations to our Japanese client SUNCORPORATION for the transaction of its Israeli subsidiary Cellebrite
Congratulations to our client BAE Systems – a multinational arms, security, and aerospace company, and one of the world’s largest defense companies,

Congratulations to our client BAE Systems for the sale of its subsidiary BAE Systems Rokar to Elbit Systems.
We recently represented the AMI fund in the sale of ZAP Group, which operates, among others, the price comparison website

We Represented the AMI Fund in the Sale of ZAP Group
Tuesday, 6 April 2021 | 17:00 – 18:30 (IST) | Webinar Special Purpose Acquisition Companies (SPACs) became the major trend in

The SPAC Attack and the Israeli Market
Dear Clients and Colleagues, We are writing to update you regarding the Draft Bill of Spousal Covenant for Persons Having

Draft Bill of Spousal Covenant
Dear Clients and Colleagues, Following requests addressed to the Customs Authority, the new directive regarding returned exports was canceled. The

New Directive Regarding Returned Exports -Update
Meir Linzen
Chairman
Corporate Tax, Employee Tax Benefits, Gaming, Indirect Taxes, Customs & International Trade, International Tax Planning, Internet & E-commerce, Investment Funds & Private Equity, Private Clients, Trusts & Estates, Tax, Tax Controversy – Disputes & Litigation, Transfer Pricing, Value Added Tax (VAT)
Amit Shelef Fattal
Associate
Corporate Tax, International Tax Planning, Private Clients, Trusts & Estates, Tax
Ilana Granditer
Tax
Mordechai (Moti) Fogel
Partner
Indirect Taxes, Customs & International Trade, Tax, Value Added Tax (VAT)
Sophie Matatyaho
Partner
Corporate Tax, International Tax Planning, Private Clients, Trusts & Estates, Tax
Eitan Ella
Partner
Corporate Tax, Employee Tax Benefits, International Tax Planning, Private Clients, Trusts & Estates, Tax
Itamar Gur
Partner
Corporate Tax, International Tax Planning, Investment Funds & Private Equity, Private Clients, Trusts & Estates, Tax
Aryeh Holtz
Associate
Corporate Tax, Employee Tax Benefits, International Tax Planning, Private Clients, Trusts & Estates, Tax
Roni Bar-Ze’ev
Associate
Corporate Tax, International Tax Planning, Private Clients, Trusts & Estates, Tax
Rotem Sheridan
Tax, Transfer Pricing
Omer Yaniv
Of Counsel
Corporate Tax, International Tax Planning, Investment Funds & Private Equity, Private Clients, Trusts & Estates, Tax
Efrat Kesler Kadmon
Partner
Employee Incentive Schemes, Employee Tax Benefits, Labour & Employment, Tax
Daniel Lipman Lowbeer
Partner
Corporate Tax, International Tax Planning, Internet & E-commerce, Mergers & Acquisitions, Tax
Ronen Avner
Partner
Corporate Tax, International Tax Planning, Private Clients, Trusts & Estates, Tax
Eyal Bar-Zvi
Partner
Commercial, Hi Tech, International Tax Planning, Mergers & Acquisitions, Tax, Transfer Pricing
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