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Shlomi Vaknin & Co. Law Firm
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Purchase Tax and Excise

Disputes over purchase tax on imports and local manufacture, and diesel excise refunds

What Is Purchase Tax and What Does It Apply To?

Purchase tax is an indirect tax under the Purchase Tax Law (Goods and Services), 5712-1952. It is levied on the import and on the local manufacture of goods specified by order, at the same rate in both cases. Fuel produced in Israel is subject to excise instead, under the Fuel Excise Law, 5718-1958. Most disputes concern the classification of the product, the price on which the tax is calculated, and diesel excise refunds.

Send us the payment demand or the assessment, and we will check the deadlines.

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When Should You Contact Us About Purchase Tax and Excise?

The most common situations involve importers, local manufacturers, and large-scale diesel consumers:

  • Customs reclassified an imported product to a tariff heading subject to purchase tax, or to a heading with a higher rate.

  • You fill, package, or assemble a product in Israel that is subject to purchase tax, and you are not sure you have registered as a dealer for tax purposes.

  • You received a purchase tax assessment on local manufacture.

  • Your application for a diesel excise refund for a heavy vehicle, engineering equipment, or a factory was denied.

  • The Tax Authority claims that diesel for which an exemption or refund was granted was transferred to another party or used for a different purpose.

  • You are planning to import a new product line and want to know the applicable tax rate in advance.

What Does the Law Provide Regarding Purchase Tax and Excise?

The Minister of Finance determines by order which goods are subject to purchase tax and at what rate. According to the Tax Authority, the list includes, among others, alcohol and alcoholic beverages, tobacco, motor vehicles, vehicle parts and accessories, and vehicle batteries. Purchase tax is a different tax from the acquisition tax paid on the purchase of real estate, which is explained on the Capital Gains Tax and Acquisition Tax page.

How the Tax Is Calculated

The rate is set as a percentage of the wholesale price, as a fixed amount, or both (section 3 of the Law). On imports, the wholesale price is the value of the goods under the Customs Ordinance, plus import duties and an additional percentage set by the Minister of Finance (section 4B). On local manufacture, the tax is calculated on the wholesale selling price. Rates change by order: the reduced purchase tax on electric vehicles, for example, rose from 45% in 2025 to 48% in 2026, after the Knesset Finance Committee approved the order in January 2026.

Classification

Where goods can be classified as either taxable or exempt, the Director may classify them as taxable. Where several taxable categories apply, the Director may impose the highest rate. This is provided in section 14 of the Law, which also addresses goods imported in disassembled parts.

Local Manufacture and Deadlines

A manufacturer of taxable goods registers with the National Purchase Tax Unit and files periodic returns, usually monthly, within 25 days after the end of the period, even in months with no taxable sales. Operations such as assembling a system of parts and reconditioning vehicle batteries are deemed manufacturing under the Tariff Order.

Under the Indirect Taxes Law, a demand for underpayment on imported goods may be issued within 5 years, and on other goods, such as locally manufactured goods, within 3 years.

Fuel Excise and Diesel Refunds

Excise is imposed by order on fuel produced in Israel (section 2 of the Fuel Excise Law). The Minister of Finance may grant, by order, a full or partial exemption or refund for fuel used for a specified purpose (section 9). According to the Tax Authority, diesel refunds are available, among others, for industrial plants using diesel as combustion fuel in production, for engineering equipment, for commercial vehicles with a gross permitted weight exceeding 4,500 kg (and from 10,000 kg only for holders of a carrier's license), for buses weighing over 5,000 kg, and for agricultural tractors.

The user must prove that the diesel was used for the designated purpose and that it was purchased directly from a licensed dealer, and must file the application within one year of the date the tax invoice was issued (sections 9(c) and 9(d)). Anyone who transferred diesel for which a refund was received, or used it in violation of the law, is liable to a financial sanction equal to double the excise refunded (section 25A(b2)).

How Do We Handle Purchase Tax and Excise Cases?

The channel for disputing the charge depends on whether the case involves an import, local manufacture, or excise, so that is the first thing we check:

  1. You send us the payment demand or assessment, the import declarations or periodic returns, and the product specifications. For excise matters, also attach the diesel invoices and the vehicle or equipment registration records.

  2. We check the deadline: 30 days for an objection to a local-manufacture assessment, 3 months from payment under protest on imports, and one year from the invoice date for a diesel excise refund application.

  3. We check the classification under the order and the price basis: which tariff heading the product falls under, what the rate is, and whether the calculation included the correct components.

  4. We file an objection, an appeal before the Customs Tribunal, or a claim, depending on the type of dispute, and request a meeting with the handling official.

  5. If no agreement is reached, we proceed to court: an appeal under the VAT Law against a local-manufacture assessment, or an action under section 154 for imports.

Who Handles Purchase Tax and Excise Cases?

Purchase tax and excise cases are handled by Adv. Udi Asa, who heads the firm's Customs practice. His area of expertise is indirect taxes, including customs duties, purchase tax, and excise. In 2023 he served as a director in the Indirect Tax department at KPMG Somekh Chaikin.

Questions & Answers

What Is the Difference Between Purchase Tax and Customs Duty?
Customs duty is levied only on imports. Purchase tax is levied on both imports and local manufacture, at the same rate. Therefore, a customs exemption under a trade agreement does not exempt from purchase tax. On imports, both are collected at the time of release, and the purchase tax is calculated on a base that already includes the customs duty (section 4B of the Purchase Tax Law).
We Only Fill and Package an Imported Beverage in Israel. Are We Considered a Manufacturer?
Most likely, yes. According to the Tax Authority, filling and packaging of alcohol and alcoholic beverages constitutes a manufacturing operation under section 10 of the Customs Tariff Order. Anyone engaged in the manufacture of goods subject to purchase tax must register as a dealer with the National Purchase Tax Unit and file periodic returns. Certain operations, such as operating a distillery, also require a license.
How Do You Challenge a Purchase Tax Assessment?
It depends on the origin of the goods. For local manufacture, an objection is filed before the Director under sections 82 through 85 of the Value Added Tax Law, which apply to purchase tax by virtue of section 5H of the Purchase Tax Law, and from there an appeal may be filed with the court. For imports, no such objection procedure exists: payment is made under protest and a refund claim is filed within 3 months (section 154 of the Customs Ordinance), and a notice of charge may also be appealed before the Customs Tribunal within 30 days.
My Diesel Refund Application Was Denied. What Should Be Checked?
First, the conditions set out in section 9(c) of the Fuel Excise Law: that the diesel was used for the purpose specified in the order, that it was purchased directly from a licensed dealer, and if purchased at a fueling station, that the station appears on the approved station list. Then the deadline, because the application must be filed within one year of the invoice date. For vehicles and engineering equipment, we also verify that they are registered for refund purposes.
We Imported a Vehicle in Parts to Assemble It in Israel. How Does This Affect the Purchase Tax?
Taxable goods imported in disassembled form, whether all at once or in parts within one year of the import of the first part, are treated as if they were imported whole on the date the last of the principal parts was imported (section 14(b) of the Purchase Tax Law). Therefore, disassembly alone does not change the tax rate.
Can a Purchase Tax Exemption Be Obtained for Goods Used as Raw Materials?
Only if there is an order granting such an exemption. The Minister of Finance, with the approval of the Knesset Finance Committee, may grant a purchase tax exemption by order and subject to conditions he prescribes, for example for imports by a specific category of persons or for sale for export (section 26 of the Purchase Tax Law). Therefore, the order and its conditions should be reviewed before the import.

Before importing a new product line subject to purchase tax, it is advisable to verify the classification and the tax base. If you have already received a demand or an assessment, send it to us along with the import declarations. Phone: 03-7705682.

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