Israeli Residence Certificates

Tax|Israeli tax|green track
Dr. Avi Nov, Adv. 
March, 2013
Circular 2/2013 published recently by the Israeli Tax Authority establishes a “green track” that may simplify the determination of tax residence for individuals who plan to immigrate to Israel and who potentially qualify for tax benefits under the Israeli Tax Ordinance. See: tax breaks to new immigrants and returning residents
The Israeli Tax Authority’s circular provides for two tracks to acquire tax residence: 
The “detailed track” – in this track an individual who does not qualify for the other track can request an advance ruling from the tax authorities and have the authorities examine the individual’s residence situation; 
The “green track” - the track is available to individuals with a low level of linkage with Israel in the 10 years before the year of arrival to Israel. In order to qualify for the green track, the individual must declare on Form 913 provided by the Israeli Tax Authority that they meet one of the following two tests: 
Test I

(1) The individual and his spouse and kids, were not present for more than 90 days in Israel in any of the 10 years before the individual arrives in Israel, and -
(2) All of the following conditions apply:
The individual did not receive benefits under the National Health Insurance Law.
The individual and his spouse and family didn't receive state-financed medical care from a health fund or hospital in Israel;
The individual and his spouse were not previously living in Israel and employed there by the State of Israel, or other Israeli employer;
The individual was not issued a final Israeli tax assessment as an Israeli resident.
The individual is not presently the subject of Israeli tax assessment proceedings by the Israeli Tax Authority.

Test II

In each of eight years in the 10 year-period before the individual arrives in Israel, the individual did not spend more than 60 days (and the individual’s spouse did not spend more than 90 days) in the country;
In each of the remaining two years of the 10-year period, the individual did not spend more than 183 days in Israel;
In the year before the year of arrival, the individual did not spend more than 60 days (and the individual’s spouse did not spend more than 90 days) in Israel;
The same conditions of Test I apply here.

If the green track application is rejected, the individual may submit a request under the detailed track procedure. Request of an individual wishing to obtain a pre-ruling under the detailed track may submit the request on an anonymous basis, in which case the request should be submitted to the International Tax Division within the Israeli Tax Authority.
See also: Israeli Tax Law on Residency
 
Dr. Avi Nov Law Offices, Israeli & international tax law 
*This article is intended for informative purposes only and is in no way to be construed as tax advice or a legal opinion
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