Direct Taxation

Direct Taxation

The tax department at Eitan, Mehulal & Sadot provides comprehensive and high-quality services to its clients in all fields of direct taxation, including income tax, international taxation, land taxation, national insurance, encouragement of capital investments etc. The firm's tax department has expertise in accompanying clients in transactions and advising companies on planning the transaction outline, obtaining advance tax rulings from the tax authority, inter alia rulings regarding employee stock options, corporate mergers and splits, tax benefits, filing objections to decisions of the tax authority, representation and in income tax appeals before the courts, tax planning for individuals, preparing opinions on various taxation issues, tax advice to Israeli residents residing overseas, and in all areas of land taxation, including combination transactions, purchase groups, residential apartments, representation before appeal committees etc.

Leading team
The direct taxation department is characterized by its partners' professional excellence, in-depth knowledge, creative and original thinking, dedication and many years of experience. All of the above, together with the department's good work relations with the tax authorities, have led to the firm's tax department being known as having one of Israel's most professional and excellent direct taxation practices.

Precedential judgments
Our tax department has represented various taxpayers in some of the most important and groundbreaking judgments reported in the field of tax in recent years. In addition, Eitan, Mehulal & Sadot's tax department has directly advised Israeli and international companies in some of the most high-profile and publicized deals in Israel in the last decade.

International taxation
The department also deals in international taxation at a very high level, while using tax planning based on international tax treaties. The tax department has close work relations with firms overseas specializing in taxation, and provides clients, with their assistance, with a comprehensive, extensive and cross-border service.

Examples of the department's recent activities:

  • Tax groundwork – Unique tax planning in the course of a transaction for the sale of an Israeli bank, the result of which was minimal tax liability for the seller.
  • Tax arrangement – Representation of a large and well-known public company in negotiation proceedings opposite the tax authority until the execution of a comprehensive tax arrangement which reduced the tax liability by millions of shekels.
  • Representation in an income tax appeal – Representation of employees of ORL in an income tax appeal regarding classification of privatization grants for tax purposes – either as a "capital gain" or as "employment income" ("Haim Nissim" judgment or "ORL" judgment). The court accepted the employees' position and in a groundbreaking judgment ruled that the privatization grants are liable for tax as a "capital gain". This is one of the most important tax law judgments in recent years, and has been widely cited and reported.
  • Representation before the appeal committee pursuant to the Land Taxation Law – The firm represented a large Israeli company before the appeal committee pursuant to the Land Taxation Law with respect to a significant issue pertaining to several different tax fields until receipt of a precedential and revolutionary judgment on the issue. Here too, the precedent that was handed down created for our client a significant tax saving in the sum of millions of shekels.
  • Advance tax ruling – Receipt of advance rulings on the issue of the granting of stock options to employees in accordance with an outline proposed by us, which is a groundbreaking precedent for many employees.
  • Tax planning and advice – The firm advised on the preparation of an outline for a merger transaction between several companies at a value of hundreds of millions of shekels, and thus assisted in reducing the tax liability to the minimum possible.
  • Encouragement of Capital Investments Law – The firm advises many companies on the Encouragement of Capital Investments Law. In addition, the firm handles income tax appeals of a number of different companies, concerning interpretive issues relating to the Encouragement of Capital Investments Law.
  • Filing of objections to decisions of the tax authority – The firm represents many taxpayers, companies and individuals, who file objections to decisions of the tax authority.
  • Decision of issues of "residence" – The firm represents several taxpayers, companies and individuals, in disputes vis-à-vis the tax authorities on the issue of the taxpayer's "residence"; some of the said disputes have ended in acceptance of our position by the competent authorities or in agreement upon a certain compromise. In addition, the firm represents before the courts (income tax appeal) taxpayers in respect of whose place of residence no agreement has been reached with the tax authority.


Partners in the Tax Department:


 Yaron Mehulal     
   Noa Lev Goldstein     Ehud Kronfeld
   Alice Abamovich    



Department Publications