International taxation

The world of economics is transnational, and as a result, there is an abundance of issues in the area of international taxation.

Moshe Mizrachi, Noach, Kriegel & Co. provides comprehensive legal consultation to companies and individuals residing in Israel who are active outside of Israel, and legal consultation to foreign residents who are active in Israel. Acting on international tax issues involves dealing with Israeli domestic law and double taxation treaties.
In recent years the practice of international taxation has focused on trust structures, the unique arrangements and tax benefits set forth in the tax laws regarding new immigrants and returning residents, (including with respect to reporting requirements to the tax authorities), and the taxation arrangements in Israeli law applying to foreign companies with ties to Israel.
These matters involve the basic questions of who an Israeli resident is, at what point a taxpayer (individual or corporation) is deemed an Israeli resident or one having renounced their residency, what weight the family unit is given when determining residency, and others.

Among other services for its clients, the firm:

• Provides tax advice, preparation and planning in international transactions and ventures, taking advantage of the treaties for the prevention of double taxation that Israel is party to.
• Acts on the tax benefit arrangements for new immigrants and returning residents.
• Acts on the matter of residency and tax returns to Israelis residing abroad.
• Acts on the establishment of and reporting to trusts.
• Acts on the matter of transfer prices.
• Acts on obtaining pre-rulings from the International Tax Division at the Israel Tax Authority.
• Provides legal opinions.
• Represents clients before the Israel Tax Authority and assessing officers in assessment proceedings related to international taxation.
• Represents clients in all courts on matters related to international taxation.