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
Congratulations to our client Playstudio Co., Ltd., an award-winning mobile-gaming developer, who became a public company through a merger with a

Congratulations to our client Playstudio Co., Ltd. who became a public company through a merger with a SPAC
Dear Clients and Friends, In a recent conference attended by high ranking officials of the Israel Tax Authority (ITA), the

The Israel Tax Authority to Advance Profit Split over Cost Plus for R&D Centers
Dear Clients and Colleagues, The Israeli Tax Authority (ITA) published a new directive regarding submitting import declarations for importing returned

New Directive Regarding Returned Exports
Our client, one of the largest private equity funds in Europe, EQT Private Equity, has made its first investment in

EQT Private Equity Is Coming to Israel
Our client, the Austrian logistics experts Knapp, is building for Shufersal, Israel’s largest supermarket chain, its new delivery system. Knapp

Our Client Knapp is Building a New Delivery System for Shufersal
Dear Clients and Friends, On January 31, 2021, the Israeli Tax Authority (the “ITA”) published two new green track ruling

New Green Track Ruling Applications
Dear Clients, Colleagues and Friends, Yesterday, the Israel Tax Authority (“ITA”) published circular 1/2021 (the “Circular”) addressing the ITA’s views

Recharge Payments relating to International Stock-Based Compensation
Dear Colleagues and Clients, For several years now, an ongoing debate around the taxation of carried interest received by investment

More Interest on the Taxation of Carried Interest
Dear clients and friends, In light of the situation of the businesses in Israel and in order to assist the

The VAT authorities’ postpones the date for submission of the monthly VAT return and the payment of the applicable VAT
Dear Clients and Colleagues, The Israeli Tax Authority (ITA) published lists of mandatory reportable tax positions for the 2020 tax

ITA published a new mandatory reportable tax position for import taxes: value of software imported with goods
Dear colleagues and clients, Regulation 15A of the Value Added Tax Regulations, 1976 (the “VAT Regulations”) stipulates that input VAT

Input VAT incurred in the provision of “meals” do not constitute “employee benefits”
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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