International Tax Lawyer

An international tax lawyer handles the taxation of individuals who live, work, or hold assets in more than one country: relocation and severance of tax residency, return to Israel, foreign-source income, and double tax treaties. An Israeli resident is taxed on worldwide income, and anyone who ceases to be a resident is subject to exit tax under Section 100A of the Income Tax Ordinance. Tell us when you plan to move and what assets you hold, and we will review your severance date before it is set.

If you have already received an assessment in Israel, the process is an objection and appeal, which we discuss on our Income Tax Lawyer page.

Most inquiries arise around a cross-border move: before departure, after it, or upon returning to Israel.

• You are planning a relocation and want to establish the date of residency severance and the asset structure before you leave.

• You have moved abroad but still spend 30 days or more per year in Israel, so the day-count presumption may apply and you may need to attach Form 1348 to your tax return.

• The assessing officer has requested documents regarding your days of stay, home, family, and bank accounts in order to determine that you remain an Israeli resident.

• You hold shares, options, or real estate abroad and want to know how much exit tax will apply and when it must be paid.

• You paid tax in another country on income that is also taxable in Israel, and it is unclear how much of it will be recognized as a credit.

• You are making Aliyah or returning to Israel after years abroad and want to know which status you qualify for and what changed in 2026.

• Your bank abroad asked for a tax residency declaration, or the Israel Tax Authority inquired about an account that did not appear in your return.

Since 1 January 2003, Israel taxes its residents on a personal basis: an Israeli resident is liable for tax on income earned both in Israel and abroad. The first question in any international case is therefore in which years you were an Israeli resident, and the second is what the applicable tax treaty provides when another country also considers you a resident.

Center of Life and Day-Count Presumptions

An Israeli resident is a person whose center of life is in Israel, determined by the totality of their ties: where the permanent home is, where the family is, where the employment and business activities are, and where the economic interests lie (definition of "Israeli resident" in Section 1 of the Ordinance). Alongside this test, the Ordinance establishes two presumptions. A person who was present in Israel for 183 days or more in a tax year, or for 30 days or more in a tax year and 425 days or more in that year and the two preceding years, is presumed to be a resident. The presumptions are rebuttable — by the individual as well as by the assessing officer.

A person who claims non-residency but meets one of the presumptions must attach Form 1348 — a residency declaration — to the annual return, together with supporting documents (Section 131(a)(5e)). The actual date of severance is determined in accordance with Income Tax Circular 1/2012. A draft bill published in July 2025 proposes replacing the rebuttable presumptions with conclusive ones, but as of September 2026 it has not been enacted, and the existing law applies. How the severance date is determined and what to attach to Form 1348 is explained on our Tax Residency Severance page.

Exit Tax Under Section 100A

A person who ceases to be an Israeli resident is deemed to have sold all assets on the day before severance. The tax on the accrued gain may be paid at that time, or payment may be deferred until the actual sale. A person who did not pay at the time of departure is deemed to have elected deferral, in which case the portion of the gain taxable in Israel is calculated on a linear basis, according to the ratio of the holding period up to severance to the total holding period. The rule also applies to employee stock options, but for those the Tax Authority allocates the gain according to the working days in each country during the vesting period. Details are on our Employee Stock Option Taxation page.

Tax Treaties and Foreign Tax Credits

When two countries consider a person a resident, the tax treaty between them resolves residency for treaty purposes and determines which country may tax each type of income. Where there is no treaty, or where the treaty allows both countries to tax, the foreign tax paid on the same income may be credited against the Israeli tax, subject to the conditions and ceilings set out in Sections 199 through 210 of the Ordinance. The credit is not automatic: it must be shown that the payment constitutes "foreign taxes" as defined in Section 199 and that it is attributed to the correct income.

Reporting Foreign Assets and Income

An Israeli resident must file an annual return — even without any other filing obligation — if the total value of foreign assets held by the resident, their spouse, and their children under 18 exceeds a threshold updated each year (NIS 2,086,000 for the 2024 return). The same obligation applies to anyone who transferred NIS 500,000 or more abroad within a 12-month period. Income from foreign assets, such as rent, interest, and dividends, must be reported and is subject to tax. The Tax Authority also receives information from banks: since 2019, Israel has been exchanging financial account information with other countries automatically under the CRS standard. Reporting obligations, FATCA for U.S. citizens, and what can still be regularized today are detailed on our Foreign Bank Accounts and Assets: Reporting and Regularization page.

New Immigrants and Returning Residents

New immigrants and veteran returning residents are exempt from tax for 10 years on income generated outside Israel (Section 14). Anyone who became a resident from 1 January 2026 onward is no longer exempt from reporting such income, following Amendment 272. A person who became a resident between 5 November 2025 and the end of 2026 may also benefit from an exemption on employment income earned in Israel up to an annual ceiling, under the Law for the Encouragement of Aliyah to Israel and Return Thereto (Temporary Provision), 5786-2026. Details are on our Taxation of New Immigrants and Returning Residents page.

Unreported Income and Assets

The voluntary disclosure procedure (temporary provision) ended on 31 August 2026. What can be done today regarding unreported foreign income is explained on our Voluntary Disclosure and Capital Regularization page.

1. You bring your entry and exit dates from Israel for the last three years, a list of assets and accounts in Israel and abroad, your employment contract or foreign business documents, and, if available, the tax returns you filed in the other country.

2. We determine your residency status for each tax year: whether a day-count presumption applies, what evidence supports severance, and what the tax treaty provides when both countries consider you a resident.

3. We calculate the exit tax for each asset and assess which option is preferable: paying now on the gain accrued up to severance, or deferring until the actual sale and applying the linear allocation.

4. We prepare the annual return for the year of severance, including Form 1348 where required and the certificate of residency from the new country. Where foreign tax was paid, we calculate the credit.

5. If the assessing officer does not accept the severance, we represent you in assessment proceedings, objections, and appeals, using the evidence we gathered from the outset.

International tax cases at the firm are handled by Adv. and CPA Shlomi Vaknin and his team. Shlomi, the firm's founder, has been a certified public accountant since 2000 and a licensed attorney since 2008. He served for nearly a decade as a national supervisor in the professional division of the VAT department at the Israel Tax Authority, and until he established the firm in 2024 he was a senior partner at a tax law firm for 18 years. In a residency severance case, this background helps in both parts of the work: calculating the exit tax for each asset and preparing the evidence the assessing officer will request.