We wish to draw your attention to amendments (the “Amendments”) to the Israeli Income Tax Ordinance (the “Ordinance”), published in the Official Gazette on December 9, 2015. The Amendments enact new reporting requirements, which came into effect on January 1, 2016. The reporting obligations relate to written opinions issued in circumstances in which the advisor’s professional fee is dependent on the recipient’s tax savings, as well as to “shelf planning” opinions. Reporting is also required in relation to positions taken that are contrary to the positions of the Israeli Tax Authority. We discuss these reporting obligations in greater detail below.
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