Tax Group

Multinational businesses are increasingly affected by tax, legislative and regulatory developments throughout the world.

PwC Israel's corporate tax practice has extensive experience supporting companies in their daily business activities as well as providing ad hoc solutions to complex tax issues arising at different business junctures.

Our aim is to comprehend our clients' business needs, with the goal of providing tax planning and solutions that are tailored to such needs. As we believe that an optimal tax model should be an inseparable component of the company's development strategy, we assist our clients in every step of their corporate development.

Our Services:

• Ongoing Corporate Tax consulting
• Representation before tax authorities, including preparation of different types of reports and obtaining pre-rulings
• Provide professional opinion papers on tax issues
• Consultation services regarding capital gains tax aspects
• Employee benefits tax planning, including stock option plans
• Support in examining tax provisions, including FIN 48
• Consult and support the implementation of corporate restructure
• Assistance with planning and implementation of corporate financial structures
• Support through M&As, including due diligence, tax structure planning, review of agreements and obtaining approvals from tax authorities, as required
• Consult on tax accounting vs. GAAP issues
• Consult regarding investment incentives and approved enterprises according to Encouragement laws

Achieving your tax objectives in today's ever-evolving global landscape requires experience and foresight. Make the best decisions to strategically move your business forward with confidence.

PwC Israel-based U.S. Tax Department is one of the largest U.S. tax practices in Israel with the largest number of tax partners and managers that were seconded for long-term periods to PwC U.S. These partners have gained substantial practical working experience in the area of U.S. taxation.

Our U.S. tax team has significant experience in providing tax planning and preparing U.S. tax return preparation services for both U.S. corporations (Form 1120) and Non-U.S. corporations with nexus in the U.S. (Form 1120F), partnerships (Form 1065) and individuals (Form 1040). We offer both advisory and compliance services to help companies address their U.S. taxation concerns, whilst leveraging on our insight to provide advice that is in line with their corporate strategy and business goals.

The U.S. Tax Department assists multinational businesses in addressing their cross-border needs, as well as in achieving a more tax-efficient global operational structure. We can support in each stage of your organization's development, beginning with structure selection and planning, through positioning companies for IPOs and mergers & acquisitions.

Our Network:

Working together with the PwC U.S. firm, we are uniquely positioned to provide our clients with a global tax perspective and full service approach to meet all their tax needs.

Our Services:

•       Value chain transformation planning
•       U.S. tax planning of mergers & acquisitions
•       U.S. tax accounting compliance and consulting services
•       Preparation and filing of U.S. federal & state tax returns
•       Controlled foreign corporations tax planning
•       Consultation regarding cross-border transaction structuring
•       Foreign account compliance services
•       U.S. inbound and outbound structuring
•       Double tax relief & foreign tax credit planning
•       Consultation regarding holding structure of intellectual property and other intangible assets
•       Conduct U.S. tax due diligence
•       US employees' compensation planning (RSU, options etc.)

Multinational businesses are increasingly affected by tax, legislative and regulatory developments throughout the world.

PwC Israel's International Tax Department offers an array of innovative solutions and tax services to international corporates, family offices and high-net-worth individuals.

We have the resources, experience and local competencies to help our clients address cross-border needs, meet worldwide demands and optimize their tax posture.

We utilize a unique, well established methodology, which enables us to provide comprehensive solutions or solve a specific problem, while receiving support from the PwC firms all over the world when required. As part of the PwC global network, we can provide you with the up-to-date analytical tax insight you need to achieve your business goals, both locally and globally.

Our services:

• Development of a global and flexible tax strategy, which facilitates an efficient growth, acquisition, and exit opportunities
• Global structure alignment, IP strategies
• Efficient structuring of cross-border investments (including real estate investments)
• Cross-border mergers, acquisitions, dispositions and restructuring
• Cross-border financing and treasury solutions
• Profits repatriation
• Transfer pricing consulting
• Utilization of global tax incentives

PwC Israel's Indirect Tax Department has extensive experience in handling, advising and overseeing a variety of indirect tax issues, including Value Added Tax (VAT), customs, purchase VAT and fuel excise tax.

The department is part of a global network, who offers solutions on a full range of services. The team of PwC Israel's indirect tax department has the tools, the experience and the knowledge to deliver the solutions you need today, and face the indirect tax challenges of tomorrow. 

Our Services

•   Handle VAT issues including indirect tax advice in everyday operation and  problem solving
•   Ongoing representation in front of the VAT authorities, including handling VAT refunds, registration    for VAT purposes, reports etc
•  Provide memorandums with respect to VAT and customs aspects
•  Applications to obtain pre-rulings from the VAT and customs authorities
•  Assistance in representing clients in audit and assessment procedures in front of the VAT authorities
• Guidance in transactions: examination, planning and implementation
• Customs and purchase VAT issues, as well as customs duties and refunds for overpayment
• Assistance and advice to foreign companies with activities in Israel
•  Assistance and advice to Israeli companies with activities abroad
• Implementation of online VAT reporting system

The Israeli government offers a wide range of incentives to companies in different industries, aimed at encouraging foreign investments in the local economy. However, the intricacies of these rules and regulations require expert, unbiased, professional advice. Our vast experience and knowledge of the law, alongside its provisions, allow us to consult our clients on maximizing their gain of these ordinances.

We assist companies of all sizes and industries, allowing them to take full advantage of government funding, benefits and incentives under several laws, including: the Law for Encouragement of Capital Investment, the Law for Encouragement of Industrial Research and Development, as well as other relevant legislation. Our clients range from startups to multi-national corporations in technology, life sciences, cleantech, industrial manufacturing and more.

Our services combine in-depth understanding of the business and competitive landscape as well as extensive knowledge of encouragement programs in Israel and abroad. Our team consists of CPAs, lawyers and technical experts, who provide creative solutions, tailored to the specific business needs of our clients. Additionally, our consultants work closely with regulators and policymakers and contribute to the frequent updates of the encouragement legislation.

Our Services :

Tax benefits

• Support in obtaining pre-rulings from tax authorities
• Writing professional memos and opinions
• Feasibility testing and calculation of effective tax rates
• Assistance in preparing financial statements and tax return disclosures 

Support for research and development activities

• Filing application for support to R&D activities from diverse sources:

1. The Israeli Innovation Authority (formerly the OCS)
2. Binational funds
3. Bilateral programs
4. Foreign support programs (e.g. Eureka, Horizon 2020, US government programs)

• Obtaining approvals from the Israeli Innovation Authority
• Support in relocation of production and/or IP to outside of Israel

Support for industrial activity

• Innovation Authority grants for investment in fixed assets
• ob creation programs of the Investments Authority
• Applications for tender-exempt allocations of industry land 

Support for international marketing and transactions

• Export encouragement and assistance programs by the Ministry of Economy (e.g. Smart Money and the Fund for Support in International Projects and Tenders)

Additional services

• Review of qualification for benefits and testing feasibility of moving between benefits programs
• Support for investors and companies in setting up and/or expanding operations in Israel and representation before Israeli government ministries and agencies
• Resolution of special issues with government entities

Our Tax Professionals advise in a variety of activities such as mergers, carve-outs, de-mergers, spin-offs, acquisitions, sales and other forms of restructuring. Our professionals have an abundance of experience in supporting sellers and buyers in all stages of the deal and after its realization.

PwC Israel's Tax Department stands out in its ability to plan Mergers & Acquisitions with foresight, emphasizing tax efficiency while creating a corporate structure that ensures that it will yield the most beneficial tax results.

Our services:

• Planning and implementing transactions, both for the acquiring entity and the target entity
• Pre-acquisition due diligence
• Handling all aspects of merging the target entity into the buyer
• Reviewing the tax efficiency of the planed structure
• Planning and implementing the merger plan
• Negotiating and obtaining advance pre-rulings from tax authorities
• Post Merger Re-Alignment, ensuring a post-deal tax efficient integration

Committed to serving the real estate community in all phases of the real estate life cycle.

Our Tax Department comprises a professional and unique Real Estate team, specializing in aspects of Income Tax, Real Estate Taxes, Corporate Income Tax, VAT and other tax issues in all stages of realty deal planning, implementation and ongoing activities in the area of real estate.

We advise individuals and corporations on real estate deals in Israel and overseas in cooperation with PwC experts around the globe.

Our services:

• Assistance in preparation and submission of Real Estate Tax Statements
• Tax advice on real estate deal planning and implementation in Israel
• Tax advice on real estate deal planning and implementation overseas
• Representation before Real Estate Tax authorities and negotiating and obtaining advance rulings

We provide a service of "central collection" with the Israeli Tax Authorities. Implementation of this arrangement allows deferral of payments to the tax authorities as well as earlier access to refunds for VAT.

In addition to standard SHAAM services, we offer a unique complementing service of a specialized review of tax accounts. The settlement accounts of corporations are examined on an
on-going basis with the purpose of settling deficiencies. The database provides access to the client’s files which facilitates tracking proper receipt of reports, current fines and other surcharge tax levies that were incorrectly levied, etc.

The highly specialized expertise of our SHAAM professionals, allows our clients to monitor the state of their account and in most cases yields considerable cash savings.

Whatever the nature of your business and whatever your industry, we have the tools, the local presence and the sophisticated, up-to-date regulatory knowledge to help you stay ahead of the TP game.

PwC Israel's Transfer Pricing Department is part of a global network with over 3,100 professionals in over 93 countries. We deliver coherent Transfer Pricing solutions that are responsive to the rapidly changing markets in which multinational corporations operate. Our team is well positioned to advise you on developing compliant, tax-efficient structures that help advance your business goals within the ever-shifting compliance landscape.

The experience accumulated both by our PwC Israel Transfer Pricing team and by our global network, allows us to effectively support you in any global transfer pricing project and to create globally aligned solutions that are both feasible and practical from a local perspective.

Our Services

• Develop global coordinated documentation in line with the new documentation requirements stemming from Action 13 of the OECD Base Erosion and Profit Shifting ("BEPS") project; including the Master File & Local File, as well as country-by-country ("CbC") reports

• Perform Value Chain Analysis, based on Actions 8-10 of the BEPS: Investigate into the functions, risks, assets and evaluate how they integrate with the group's key value drivers

• Develop coordinated transfer pricing documentation that takes into account the requirements of each jurisdiction

• Assist multinational entities to plan and implement local & global transfer pricing policies

• Perform benchmark analyses for all types of intercompany transactions including tangible, intangible & financial transactions

• Negotiate advance pricing agreements ("APAs") with tax authorities

• Support multinational entities during transfer pricing audits with local & foreign tax authorities

• Lead global dispute resolutions

• Evaluate reserves necessary for transfer pricing related uncertain tax positions (e.g., FIN48)

PwC’s global Transfer Pricing network has over two decades of delivering innovative, effective, forward-thinking solutions. Wherever you do business.

PwC Israel's Individual Tax Department helps high-net-worth individuals and families to optimize their tax position,
and comply with all necessary reporting requirement to different tax authorities in Israel and overseas.

Our team includes highly-experienced attorneys, CPAs and tax consultants with deep knowledge of what individual taxpayers need within their distinctive business environment. We understand that every client's situation is unique,
and for that, we tailor our professional services to provide the right solutions, with utmost privacy and confidentiality.
In addition, all our firm's other tax services are available to provide clients with comprehensive solutions for the entire spectrum of tax issues.

Our Services:

• Preparation and submission of Israeli annual tax returns
•  Preparation of Israeli individual capital statements
• Consult and support tax aspect in share purchase/sales (including foreign tax aspects)
• Negotiate and obtain pre-rulings for equity transactions
•  Consult regarding rights allocation to employees and special compensation arrangements
• Consult regarding tax aspects of pension, retirement and related benefits
• Consult regarding tax residency
• Consult regarding tax aspects of trusts
• Assist with voluntary disclosure
• Assist with tax audits of individuals, including pension-related aspects
• Tax withholding and National Insurance audits for companies
• Obtain various approvals, including resource transfers overseas
• Voluntary reviews of withholding and bookkeeping
• Consult regarding complex issues concerning securities portfolios
• Obtain various approval from tax authorities, including resource transfers to outside of Israel and employee relocations
• Representation before the Israel Tax Authority and the National Insurance Institute, including initial registration

We have the tools, the knowledge and expertise to upgrade your compliance, and by that to reduce tax exposure, streamline processes and save valuable resources.

Over the last few years, a slew of new regulations require more and more electronic reporting. This is why PwC Israel's Tax Group has established a new department, specializing at IT compliance relating to tax and other related domains. Our team have rich experience in providing professional advice to leading organizations in the Israeli economy. Our experts assess conformity of IT systems with key regulatory provisions in Israel, such as Income Tax Rules (Bookkeeping)- 1973, the Income Tax Ordinance, withholding regulations, the Value Added Tax Law, 1976 and more.

Our services include analyzing any gaps between processes/systems and provisions in tax law, and then providing recommendations as to the best avenues to close those gaps. Follow-up tests are later implemented to examine resolution actions. We aim to optimize the tax IT compliance to keep your company at the forefront of compliance.

Our Tax IT Compliance Leader, is a CPA and also a qualified data analyst and computer programmer. The team provides personalized services and a broad scope of customized solutions. 

Our Services

Efficiency and savings:

•  E-documents – consult regarding implementation and integration of systems   for sending invoices via email
• Assess compliance of existing processes with bookkeeping regulations
• Consult regarding implementation of invoice e-archives (including examination of existing processes and systems)

Legal framework:

• Support in localization of IT systems, to comply with bookkeeping provisions (including software registration): online VAT reporting, tax withholding reporting, Form 6111 (filing financial statements to Israel Tax Authority(ITA)), producing files using the format mandated by ITA, and reporting PPEs (including depreciation and capital gains)
•  Support for taxpayer in preparing for online reporting, including: VAT, withholding (Form 856), excise refunds, etc.
• Handling rejections of books of accounts and tax audits; suggest resolution to comply with court rulings
• Preparation for compliance with uniform file format requirements, including analysis and reduction of related exposures