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
On January 17, 2019, Israel and the UK signed a significant Amending Protocol to the 1962 Income Tax Treaty between

Client Update | Revisions to Tax Treaty between Israel and the United Kingdom
On December 16, 2018, the Israel Tax Authority (the “ITA”) published a notice that companies remunerated under the Transaction Net
Client Update | New Notice of the Israel Tax Authority Regarding Stock Based Compensation: Amendment of Tax Returns following the Supreme Court Ruling in the Kontera and Finisar Cases
This is an important update for multinational groups with business activities or affiliates in Israel, and is particularly relevant for
Client Update | Change of a Business Model in Multinational Groups
Recently Israel informed the OECD that it has ratified the Multilateral Convention to Implement Tax Treaty Related measures to prevent
Tax Client Update | Israel Ratifies the MLI
The Israeli Tax Authorities (“ITA”) recently published two safe harbour circulars, which have been in draft mode for several months,
Client Update | The Israeli Tax Authorities Set New Safe Harbour Rules for Certain Transfer Pricing Transactions
Recently, a District Court judgement relating to the issue of the deduction of input tax by a holding company was
Client Update | Deduction of Input Tax by Holding Company
BDI Code has published its 2018 Israel Legal Rankings, where, once again, our firm has been ranked the leading Israeli

BDI Code’s Ranking for 2018: Herzog Fox & Neeman ranked leading law firm in Israel!
Herzog Fox & Neeman’s Managing Partner, Meir Linzen, participated in the lead panel of the Annual Israel Bar Association Conference,

Meir Linzen talks Tax at 2018 Israel Bar Association Conference
On May 6, 2018 a revolutionary decision of the Supreme Court in the Or Sarah case, was published. The decision determines that
Tax Client Update | Revolutionary Case Law Changes the Capital Gain Calculation with Respect to Foreign Securities
On May 6, 2018 a revolutionary decision of the Supreme Court in the Or Sarah case, was published. The decision
Tax Client Update | Revolutionary Case Law Changes the Capital Gain Calculation with Respect to Foreign Securities
On April 22nd 2018 the Supreme Court issued its much anticipated court ruling on two appeals which were consolidated into
Client Update | Supreme Court Ruling – Inclusion of Equity Based Compensation in Cost Plus Arrangements
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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