Israeli Tax Ruling on Residence 

Individual| tax treaty|resident

Dr. Avi Nov, Adv. 

April, 2013 

The Israeli Tax Authority published a tax ruling on 2 December 2012 in which they granted an Israeli tax residence certificate for purposes of the applicable tax treaty. See: Israel tax treaties

In this case an individual and his spouse owned a global production business. They spent most of their time traveling between the countries in which their business is located. They moved to Israel and submitted a request to the Israeli Tax Authority to be considered Israeli residents for purposes of the relevant tax treaty. 

The Israeli Tax Authority ruled in favor of the couple since they had passed the physical presence tests with respect to the preceding three years. In this case, the couple stayed in Israel for more than 100 days in the earliest preceding year, more than 133 days in the second year and more than 143 days in the third year. They also submitted a commitment to be present in Israel for more than 143 days in each of the two following years. 

There were a few conditions to the decision, but the main condition was that the couple should have a permanent home available to them during their stay in Israel. 

See also:

Israeli residency: New Israeli Tax circular

Israeli Residence Certificates

Israeli Residence for tax purposes

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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