When expanding business interests is overseas, the tax analysis will be more complicated and must be taken into account the tax laws in different countries and agreements between the countries about "tax cake distribution". In last 10 years, the distribution becomes more complicated because implementation of new tax rules of OECD, like BEPS, Transfer Pricing and many other. For growing high-tech companies, it could be complicated twice because diversity of employee’s incentive and capital instruments. Our purpose is prevention unnecessary tax risks for our customers. We provide a following kinds of service
- Tax planning and optimization. In situation when some business entity in one country has related party (branch, subsidiary, invested company) in other country or number of companies in different countries belong to same person or entity, some transaction between these sides considered as Related Party Transaction and be subject of additional regulation. We help to our client to build the group taxation map and understand what percent/amount of tax the group should pay. We provide our knowledge and experience to use tax incentive and international tax treaty tom optimize the tax costs.
- Transfer Prices. On of main OECD regulation in related party deals is defining of fair value of transfer price. We have experience to define optimal transfer price with according to Comparable Uncontrolled Price, Resale Price, Cost+, Transaction Net Margin and Transaction Profit Split methods. We know to choose most suitable transfer price method, tom implement the pricing structure algorithm at the customer business and prepare a relevant (master file, local file) transfer price documentation for.
- Incentive Taxation. Most usual incentive for employees and managers are Restricted Stock Units (RSU), Employee Stock Option Plan (ESOP) and Employee Stock Purchase Plan (ESPP)/ We can to recommend an optimal method for certain business entity. As well, we prepare a relevant tax documentation including 409a valuation.
- M&A Tax Issue. Israeli tax laws related to business merger, splitting, spin-off and restructuration are enough complicated. Sometime, incorrect agreement could lead to tax pitfall. Whelp to our customer to build an optimal deal without and additional tax risks.
- Documentation support. Foreign investors, as well new Israeli citizens obtaining status of Ole Hadash meet misunderstanding in banks and tax authorities in Israel regarding to approving of sources of their incomes and assets. Sometimes, the banks freeze the client’s financial assets or refuse to receive foreign wire to the client’s Israeli bank account. We engaged in preparation of relevant documents and confirmation to Israeli banks and tax authorities include relevant FATCA and CRS form. We also have experience to solve a problem when bank already freezes the client’s bank account.
Our office to get advice on various issues related to taxation in Israel, USA, EU, CIS include Russia and other countries. We have network with colleagues abroad, having expertise in taxation and we can provide you service in many countries around the world.
Representation before tax authorities
Our office represents clients for the tax authorities on issues including negotiations problematic. We aim to give customers the most convenient communications with tax authorities. We are linked directly with the information systems of the Ministry of Finance which allows us to offer services online. Sometimes our work involves the preparation of a compromise agreement and submitting internal appeals .
Sometimes, tax ambiguity does not provide a business manager to get evaluation or an opinion, but situation requires certainty on the issue of current or future tax. In such situations the only solution is to make a decision preliminary tax (pre-rulings) when the taxpayer places the issue before the tax authorities and reaches an agreement with them in advance. We handle preparations for pre-rulings business moves to avoid uncertainty states early stages tax relief and tax decisions preliminary tax assessor and manager.
Sometime, new Israeli citizens convinced by some Jewish Agencies, that after obtaining status of Ole Hadash they will not be able to pay any taxes related to their business or assets abroad. Sometime, the information is not correct because limitation of the tax law. To minimize unpleasant tax consequence in future, we recommend to people with net worth of $1 million and more, to submit a ruling with relevant document confirming the compliance the certain case to tax law and exemption of certain income from Israeli Taxes. Our customers get official confirmation of Israeli Tax Authority regarding to the tax exemption.