Mergers & Acquisitions, divestitures, and asset transfers

Economic activity of large entities requires corporate flexibility and the ability to make dynamic changes to the group’s structure without incurring tax liabilities.

Arrangements for structural changes in tax law are intended to enable corporations operating within a group to organize the holding structure in order to reduce friction between the economic-legal considerations of the group’s structure and tax considerations in Israel and abroad. The legislation dealing with the area is complex and convoluted and in most cases is not uniformly interpreted by the tax authorities and courts.
Proficiency in tax legislation dealing with structural changes and an in-depth understanding of the principles underlying the various arrangements enable flexibility in arranging the group’s activity, while avoiding the creation of tax exposures, on the basis of long-term planning. In this area the legislature requires statutory pre-ruling approval from the tax authorities in many number of situations
The practice of structural changes at Moshe Mizrachi, Noach, Kriegel & Co. is led by Adv. Eldad Noach, who served as head of the Mergers and Divestitures Department in the Professional Department of the Israel Tax Authority. Noach was one of the most prominent figures outlining the Israel Tax Authority’s policy on the subject, and was involved in hundreds of tax rulings on the subject, where the Israel Tax Authority actually implemented them as policy.