Business Model Canvas (BMC)- A new venture concept
Aitc presentation by ahec
1. 1
AITC AGM 2019
Utrecht, the Netherlands
Artzi ,Hiba & Elmekiesse, Cohen – Tax Solutions presentation
Presented by
Hagi Elmekiesse, C.P.A, (Adv.)
Gadi Alimi, C.P.A, (Adv.)
Israeli member of AITC since 2018
6th - 7th of September, 2019
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Voluntary Disclosure
• Regularization of unreported assets and foreign bank accounts;
• Very relevant due to the instructions of the FATCA and CRS
combined with the leakage of bank information;
• Hundreds of cases of voluntary disclosure in front of the Tax
Authority;
• Most of the cases are submitted anonymously.
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Trust Taxation and settlements
• In 2006 legislation regarding trust taxation enacted for the first time;
• In 2014, a major changed introduced in the trust taxation;
• No more exemption for “Foreign Settlor Trust”;
• Achieving tax settlements with ITA for Trusts;
• Special rates apply on unreported trusts assets (3%-10%);
• Anonymous application for trusts settlements;
• Allowing to achieve settlement with “link to Israel” (family/assets).
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Cryptocurrency taxation
• Cryptocurrency as “asset” or ”currency” ?
• Lately, district court ruling that cryptocurrency is considered an “asset”!
• Substantial tax liability due to exchange of coins (mainly in 2017);
• Negotiations with Israeli tax authorities for tax settlements to individual
investors in cryptocurrencies;
• Pre-Ruling about fees received in Cryptocurrency;
• Advising ICO initiations (timing for the recognition of income for the
enterprise, employees, providers of services, etc.).
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Gadi Alimi
Gadi Alimi, C.P.A, (Adv.)
Partner, Specialist in International Taxation
Background:
• 11 years of service at the Israeli Tax authority at various
positions and assignments, among them:
• Assessing officer
• Issuing of pre-rulings
• Participations in legislation processes
• Writing of circulars
• Handling of complex cases involving international
taxation.
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6
Gadi Alimi
Gadi Alimi, C.P.A, (Adv.)
Partner, Specialist in International Taxation
Specialization
1. International tax structures
2. Residency of individuals and companies
3. Tax incentives for new immigrants and veteran returning
residents
4. Tax Benefits for foreign residents and acquirement of state
incentives for corporations operating in Israel.
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International tax structures
• Israel has a relatively large network of tax treaties with 55 countries
(and growing…);
• Member of the MLI-treaty;
• Many Israeli individuals and companies are investing around the
globe, mainly in through the USA, the UK, Spain, Portugal,
Greece, Germany, the Netherlands, Malta and Cyprus;
• Tax structures with consideration to Estate planning (no IHT in
Israel).
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IL
No branch tax in Israel
CY
Activity in
Israel
Israeli CIT
30%
23%
0%
Israeli WTT
on dividends
CY
Activity in
Israel (PE)
Israeli CIT
0%
23%
0%
NO WTT
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Residency of individuals and Companies
Body of persons
• A person other than an individual is considered an Israeli resident if either one of the
following is met: if it was incorporated in Israel or the “management and control” over
its business is exercised within Israel;
• Expected legislation reform: Deemed tax residency;
Individuals
• New Supreme court decisions concerning Israeli Tax Residency (Michael Sapir) about
disconnecting the family unit;
• The Israeli law sets 2 legal presumptions (rebuttable presumption) for determination of
individual's “center of life” is located in Israel;
• Foreign residency from “Day 1”.
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• Significant tax benefits to New Immigrants and former Israeli
residents who resided at least 10 years outside Israel;
• Full exemption for a period of 10 years applies to all types of
foreign-sourced income: Passive income and capital gains
deriving from foreign assets (including those acquired after
immigrating to Israel), business income and income from
employment and professional services carried outside of Israel;
• Exemption from filing and reporting duties for 10 years;
• Exemption from “Management and Control”.
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Tax incentives for new immigrants and veteran
returning residents
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Tax Benefits for foreign residents and acquirement of
state incentives for corporations operating in Israel.
• Exemption from tax on capital gains;
• Exemption from tax on investment income;
• Application to foreign investors in investment funds operating and
investing in Israel:
• VC Funds- Full exemption on all kind of income (Capital Gain, dividends,
interest);
• Private Equity Funds- Exemption on Capital Gain (exemption on dividends
and interest only to income attributed to “Exempt Foreign Investor”).
• Law for Encouragement of Capital Investment;
• Participation Exemption.
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Law for Encouragement of Capital Investment
Benefits and conditions – “Preferred enterprises”
• Lower Corporate Income Tax rates: 7.5% in priority regions and
16% in other regions (instead of 23%);
• Lower tax rates on dividends distributions: 4% if 90% held by a
foreign corporation, 20% in other cases (subject to DTT lower
rates) (instead of 25%-30%);
• Accelerated depreciation expenses (200%, 400%);
• Possibility of entitlement for both grants and tax benefits;
• The law applies also to indirect exporters;
• Conditions:
• industrial activity,
• export requirement (25% of the revenues),
• Other conditions.
