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Voluntary Disclosure Has Ended: Israel Tax Authority Data and What the Options Are Now

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What Happened to the Voluntary Disclosure Procedure?

The Israel Tax Authority's Voluntary Disclosure Procedure ended on 31.8.2026, and no new applications can be filed under it since then. According to the Authority's announcement dated 7.9.2026, a total of 823 applications were submitted by the deadline, with declared capital of approximately NIS 1.89 billion. As of 16.10.2026, no new procedure or extension has been published. Anyone who has not yet regularized unreported income or capital may still amend their tax returns, but without the protection from criminal proceedings that the procedure afforded to those who met its conditions.

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Key Figures

The procedure was in effect for approximately one year, and roughly half of all applications were submitted in its final month.

  • Procedure period: From 25.8.2025, the date the Temporary Order was published, through 31.8.2026.

  • Applications filed: 823, approximately half of which were submitted in August 2026.

  • Declared capital: Approximately NIS 1.89 billion, with an estimated tax principal of approximately NIS 152.6 million.

  • Scope: Income tax, VAT, customs, and real estate taxation.

  • What the procedure offered: Payment of the full tax liability and avoidance of criminal proceedings, subject to conditions.

  • Official source: Israel Tax Authority announcement dated 7.9.2026.

What Changed and When

The track that shielded applicants from criminal proceedings closed on 31.8.2026. It was not the first of its kind: according to the Israel Tax Authority, similar procedures that operated in 2011–2012, 2014–2016, and 2017–2019 handled approximately 9,000 cases and collected roughly NIS 5 billion in tax.

  1. 25.8.2025: Publication of the Voluntary Disclosure Procedure (Temporary Order 2025), approved by the Attorney General. Only identified applications could be submitted, via an online form.

  2. Income Tax Execution Directive 10/2025 established two tracks: a tax assessment agreement with the assessing office, or a "green track" involving the filing of amended returns. For rental income, an abbreviated reporting method at a rate of 10% was prescribed.

  3. August 2026: Approximately half of all applications were filed during this month.

  4. 31.8.2026: The procedure's effective period ended.

  5. 7.9.2026: The Israel Tax Authority published the final data.

What the Data Reveals

Rental income appeared in 324 applications — the highest of any category — with declared capital of approximately NIS 358.2 million and an estimated tax of approximately NIS 32.3 million. Applications involving digital assets were fewer (203), but the capital reported in them was higher: approximately NIS 482.5 million, with an estimated tax of approximately NIS 51 million. Overseas bank accounts appeared in only 197 applications, yet they concentrated the largest amount of capital, approximately NIS 623.1 million.

The Authority itself qualifies these figures. A single application may cover multiple categories, resulting in overlap between the groups. The data also includes applications that have not yet been approved, and the amounts are based on applicants' declarations and do not necessarily reflect the tax that will ultimately be collected.

Who It Applies to and Who It Doesn't

The closure blocks only new applications. Anyone who filed by 31.8.2026 continues through the process: the Investigation and Intelligence Division examines whether the application meets the procedure's conditions and issues a letter of approval or rejection. The approval letter determines the processing track and refers applicants to the civil tax office.

Those who did not file an application

The obligation to report and pay has not changed. Under Section 145 of the Income Tax Ordinance, the Assessing Officer may issue a reassessment within 4 years from the end of the tax year in which the return was filed. On the criminal side, Section 220 of the Ordinance prescribes up to 7 years' imprisonment for anyone who willfully omitted income in order to evade tax, and the statute of limitations for this offense is 10 years under Section 225.

Even when the procedure was open, it was not suitable for everyone. Anyone who was already under investigation or audit by the Tax Authority, or about whom the Authority already held information, did not meet the conditions — nor did anyone previously convicted of a tax offense or who had paid a monetary settlement (kofer).

What to Check Now

The first step is to map out what was not reported, for which tax years, and from what source — before submitting anything to the Authority.

  1. If you filed an application before 31.8.2026, verify that you received an approval or rejection letter and which track you were assigned to. The protection is contingent on full and honest disclosure, and Sections 23–29 of the procedure set out exceptions.

  2. If you have unreported rental income from residential property in Israel, review Section 122 of the Ordinance: a 10% tax on rental payments instead of the marginal tax rates, provided the income is not business income. According to the Tax Authority's annual return guide, late payment carries linkage differentials and interest.

  3. If the funds are in an overseas bank account, bear in mind that Israel receives information on financial accounts from foreign tax authorities under the CRS standard.

  4. If the matter involves cryptocurrency, the Finance Minister announced on 20.11.2024 a commitment to adopt the CARF standard for the exchange of information on digital assets starting in 2027. On 6.10.2026, the Israel Tax Authority published two investigations into suspected concealment of income from digital currencies, which we detailed in ourarticle on the October 2026 crypto investigations. The remaining options for investors are detailed on our Voluntary Disclosure for Crypto page.

  5. Before filing an amended return, assess the criminal exposure. Outside the procedure, amending a return settles the tax liability, but it does not include any commitment by the Authority to refrain from initiating criminal proceedings. In cases where proceedings have already been opened, Section 221 of the Ordinance allows, in appropriate circumstances, for the matter to be resolved through a monetary settlement (kofer), with the taxpayer's consent.

The available options and the exposure associated with each are detailed on our Regularizing Capital After the Procedure Closed page. This area is handled at the firm by Adv. and CPA Shlomi Vaknin, who served for approximately a decade as a National Supervisor in the Professional Division of VAT at the Israel Tax Authority.

Questions & Answers

Is a New Voluntary Disclosure Procedure Expected?
There has been no official announcement to that effect. As of 16.10.2026, the Israel Tax Authority has not published a new procedure or an extension. In the past, such procedures were launched in 2011, 2014, 2017, and 2025, but this does not guarantee another one, and in the meantime unpaid tax continues to accrue linkage differentials and interest.
Were All 823 Applications Approved?
Not necessarily. According to the Israel Tax Authority, the data includes applications that have not yet been approved or whose processing has not been completed. The capital and tax amounts are also based on applicants' declarations, and the actual tax will be determined upon completion of the review.
I own a rental property abroad and have not reported the rental income. What is the tax rate?
Under Section 122A of the Ordinance, an individual may pay 15% on rental income from real estate outside Israel, instead of the marginal tax rates, provided the income is not business income. If the property was purchased with unreported funds, the review also covers the source of the capital used for the purchase.
Did the Procedure Also Apply to VAT and Customs?
Yes. It applied to all tax divisions: income tax, VAT, customs, and real estate taxation. Since the procedure ended, no such track exists in any of them.
The information in this article is general in nature only and does not constitute a substitute for individual legal advice.

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