Tax Experts
Leading in Israel
Our expertise, professional knowledge, and extensive experience
enable our firm to provide a wide range of tax services.
Shai Ben-David
Shai Ben-David, CPA (L.L.B), is the founder and owner of the firm. Shai is one of Israel's leading tax experts, advising on complex transactions involving international corporations, various investment instruments, and private investors.
Shai specializes in a large of tax areas: individual income tax, corporate income tax, international taxation,residency termination, new immigrants and returning residents, implementation of tax treaty provisions, MLI, trust taxation, voluntary disclosure, Encouragement of Capital Investment Law, mergers and acquisitions, and more.
Shai writes tax opinions, represents clients before the Israeli tax authorities (ITA) in disputes, writes applications for pre ruling, advice clients in voluntary disclosure procedures, and more.
Our expertise, professional knowledge, and years of experience enable our firm to provide a wide range of tax services.
Our firm has extensive experience in providing international tax consultant to Israeli residents and companies operating worldwide. Furthermore, we assist foreign companies and non-residents in their business activities in Israel.
Our firm international clients support includes a comprehensive and fundamental approach to various tax issues arising from both Israeli law, foreign law (through local tax advisors), and provisions found in double tax treaties, MLI, and more.
We are also advise and accompany intergenerational transfers while providing consultancy in the field of trust taxation, tax benefits for new immigrants and returning veteran residents, and international tax planning for private business individuals.
General
Our firm accompanies business individuals (both Israeli residents and non-residents) from the initial stage of examining the transaction execution path (sale/investment) up to the final stage of reporting to the ITA.
The service includes addressing various tax aspects and occasionally providing professional opinions, writing application for pre ruling.
Personal Taxation
Amendment 168 to the Income Tax Ordinance aims to encourage the immigration and the returning of Israelis living worldwide.
The amendment stipulates tax exemptions and reporting exemptions for income generated or accrued outside Israel, such as: business income, employment, interest, dividends, rental, annuities, allowances, and capital gains from the sale of assets originating outside Israel.
Our firm assists new immigrants, returning veteran residents, and returning residents in their ongoing business conduct while optimally utilizing the tax benefits they are entitled to.
New Immigrants, Returning Veteran Residents, and Returning Residents
Our firm assists individuals who are Israeli's residents in the process of terminating their residency and settling in a foreign country. The guidance includes examining the timing of residency termination, proper implementation of legal regulations concerning exit tax, reporting to the ITA, and appropriate planning to prevent double taxation between countries, including tax planning related to those who hold financial instruments such as stock options and/or shares during the period they transfer their center of life to the foreign country. Our firm provides professional tax opinions on residency termination matters, assists individuals in thier tax negotiations with the ITA, tax arrangements, and applications for advance tax rulings.
Residency Termination
Our firm possesses extensive knowledge in the field of intergenerational transfers and trust taxation. We regularly assist with intergenerational transfers, utilizing various instruments and arrangements such as wills, trusts, private endowments.
Intergenerational Transfers and Trust Taxation
Employee and executive compensation in the form of stock options and/or shares allocation is a key issue for any company. Various compensation mechanisms have been developed over the years to retain employees and recruit high-quality personnel.
Adopting compensation mechanisms requires specific attention to the Income Tax Ordinance regulations from both the company and the employee/executive. Our firmassists companies, employees, and executives in making decisions regarding the appropriate mechanism adoption, implementation, and reporting to the ITA. In cases where professional questions arise, our firm supports clients through applications for tax rulings, professional tax opinions, representation before tax ITA in tax negotiations, and more.
Capital Incentives – Employee and Executive members compensations
The world of cryptocurrencies and its various derivatives involve numerous taxation issues under both Israeli and foreign law.
Our firm supports and advises business entrepreneurs who hold and/or operate using cryptocurrencies. The consultation includes both the analysis of relevant taxation issues specific to the activity and, if necessary, addressing the ITA to arrange the activity and its taxation method.
Cryptocurrency Taxation
Our firm has extensive experience in assisting clients with voluntary disclosure processes. This process, aimed at bringing "peace of mind" and financial security to the applicant, is accompanied by our firm from the preparation of the application to obtaining the desired approval from the ITA.
Voluntary Disclosure
International taxation
Our firm has extensive and rich experience in managing international projects. We accompany Israeli and foreign residents, as well as Israeli and foreign companies, in their business activities around the world, including the following topics:
Global Real Estate Investments
Individuals and companies, both Israeli and foreign residents, invest in properties across various countries worldwide and in Israel. Our firm accompanies and advises individuals and businesses from Israel and abroad who invest in real estate in different countries around the world and in Israel. Our consultation includes an examination of tax regulations in the relevant country (through local advisors), tax implications in Israel, and reporting requirements in each country.
Tax Treaties and MLI
Our firm has extensive knowledge of tax treaty provisions designed to prevent double taxation. By wisely utilizing these tax treaty provisions, businesses can engage in smart operations that take into account tax aspects in each country and even avoid double taxation.
The MLI (Multilateral Instrument) agreement, which aims to harmonize tax treaties to prevent double taxation among different countries, is an integral part of the aforementioned approach. The MLI is a broad project initiated by the G20 forum in collaboration with the OECD (Organization for Economic Co-operation and Development) to prevent base erosion and profit shifting (BEPS) to tax havens.
International Transaction Support
Our firm provides support for numerous transactions involving international tax aspects. Among other services, we assist buyers and/or sellers in structuring deals, analyzing tax issues , and collaborating with international tax advisors from other countries. We ensure full coordination throughout the process, including seeking advance tax rulings, applying for tax withholding approvals.
International Business Activity Support
Our firm provides ongoing support to Israeli and foreign companies in the proper management of their international business activities. We offer guidance and analysis of the implications of establishing the effective management both within and outside of Israel, tax withholding rates on various sources of income, and more. Our firm represents numerous companies in front of the ITA on matters of "effective management" and the tax implications resulting from this issue.
Transfer Pricing
In recent years, determining transfer prices between related parties has become an essential and integral part of the international business world.
Our firm supports Israeli and foreign companies in examining their international transactions and planning their transfer pricing policies according to the needs of their multinational organization.
