Voluntary Disclosure in Israel: What Comes Next?

What can you do when income, accounts, or assets were not properly reported, and no voluntary disclosure procedure is currently open?

The voluntary disclosure procedure has ended. The underlying tax issue may not have.

Individuals, families and businesses with Israeli tax exposure may assume that the opportunity to resolve a reporting issue has disappeared. This may include foreign residents with Israeli-source income or assets, companies conducting activity in Israel, people planning to immigrate to Israel, returning residents and individuals with financial ties to Israel.

In practice, the end of the procedure does not cancel existing reporting obligations and does not necessarily mean that no solution can be considered.

The key question is no longer only whether a voluntary disclosure procedure is available. The key question is which regularization route may be appropriate for the specific circumstances, and what should be done before approaching the Israel Tax Authority.

The short answer

The 2025 Voluntary Disclosure Procedure ended on 31 August 2026. New applications can no longer be submitted under that procedure.

However, depending on the facts, it may still be possible to consider options such as:

Amending tax returns;
Filing missing returns;
Reporting previously undisclosed income or assets where required;
Calculating and settling tax liabilities;
Correcting accounting or tax records;
Making a planned and professionally managed approach to the Israel Tax Authority;
Establishing an appropriate reporting and compliance framework going forward.

This is not an automatic process, and it does not create automatic immunity or protection from proceedings. Each case requires a separate review of the facts, documents, relevant tax years, and potential exposure.

According to the Israel Tax Authority’s official announcement, 823 applications were submitted under the procedure. The applications included declared capital of approximately NIS 1.89 billion and estimated tax liabilities of approximately NIS 152.6 million. These figures are based on applicants’ declarations and may be subject to further examination.

Israel Tax Authority announcement regarding the end of the Voluntary Disclosure Procedure

What was the Voluntary Disclosure Procedure?

The Voluntary Disclosure Procedure was designed to allow taxpayers to correct reports, disclose previously undisclosed income or assets and pay the relevant taxes, subject to the procedure’s conditions and approval by the competent authorities.

Subject to those conditions, the procedure could protect from criminal proceedings in relation to the matters disclosed. This protection was not automatic and depended on compliance with the procedure and the approval of the relevant authorities.

The procedure could be relevant to situations involving:

Foreign bank accounts or investment portfolios;
Rental income;
Undeclared business or professional income;
Assets that were not included in previous reports;
Gains from the sale of assets or investments;
Digital assets;
Companies, partnerships or other structures that were not properly reported.

The procedure generally required full disclosure, good-faith conduct, correction of the relevant reports, and payment of the resulting taxes. A central condition was that the taxpayer’s approach should take place before the Israel Tax Authority or another enforcement authority had already begun acting in relation to the taxpayer or the relevant information.

For historical background, see AUREN’s earlier article on voluntary disclosure procedures. That article relates to earlier arrangements and should not be treated as a description of the current legal position.

What does the end of the procedure mean?

The end of the procedure has several important implications.

New applications cannot be submitted under the expired procedure

The temporary framework is no longer open to new applications. A form or submission based on the previous procedure should not be assumed to provide the same treatment or protections.

Existing reporting obligations remain

The end of the procedure does not erase income, accounts, assets, or past events. It also does not eliminate the need to examine whether reporting obligations existed in Israel or in another country.

Timing and method still matter

An incomplete, inaccurate or unplanned approach may create unnecessary difficulties. In complex cases, it is important to understand the complete factual picture before deciding how to proceed.

Anyone who submitted an application before the procedure ended should review the status and treatment of that application based on the relevant facts, the Israel Tax Authority’s instructions, and the documents submitted.

Can tax matters be regularized without an open procedure?

In some cases, yes. However, there is no single alternative procedure that applies to everyone who failed to report.

The possibility of regularization may depend on:

The type of income or asset;
The relevant tax years;
Where the income was generated;
The individual’s tax residence in each year;
Whether tax returns were filed in the past;
The amounts involved;
The source of the funds;
Whether business activity was involved;
Whether the Israel Tax Authority already holds relevant information;
The relationship between Israel and any other country involved.

Even when no voluntary disclosure procedure is open, it may still be possible to examine a structured process involving corrections, late filings, tax payments, communication with the authorities and future compliance planning.

Four steps for assessing the situation

Build a complete factual map

The first step is to collect the available information, even where it is incomplete or difficult to organise:

Bank accounts;
Investment portfolios;
Real estate;
Rental income;
Business activity;
Companies and partnerships;
Digital assets;
Inheritances and gifts;
Loans and transfers of funds;
Tax returns filed in different countries;
Correspondence and supporting documentation.

The objective is to understand the complete picture before deciding whether and how to report.

Classify the issue

Not every reporting failure is the same. It is important to distinguish between:

Income that was never reported;
A tax return that included inaccurate information;
An asset that was omitted from a report;
An incorrect tax residency position;
An undisclosed bank account or investment;
A matter involving digital assets;
A mismatch between Israeli and foreign tax reporting;
An accounting or corporate reporting issue.

The classification affects the appropriate course of action, the documents required and the level of potential exposure.

Assess the available courses of action

Once the facts have been mapped, possible courses of action may include:

Amending tax returns;
Filing returns that were not submitted;
Reporting income or assets;
Settling outstanding tax liabilities;
Making a structured approach to the Israel Tax Authority;
Reviewing tax residency issues;
Coordinating with professionals in other countries.

The decision should be based on the complete picture rather than an attempt to find a quick or partial solution.

Implement the solution and address the future

Regularization does not end with the submission of one document. It is also important to ensure that, going forward:

Returns are filed on time;
Income is classified correctly;
Supporting documents are retained;
International activity is properly documented;
Reporting in different countries is consistent;
An appropriate compliance process is established.

Who should consider a review?

A review may be appropriate where there are:

Foreign bank accounts or investments;
Rental income that was not reported;
Undeclared business or professional income;
An inheritance or gift that was not properly documented;
Assets acquired in the past that were not reported;
Gains from digital assets;
Companies, trusts or partnerships in other countries;
Differences between Israeli and foreign tax reports;
Unclear tax residency;
A connection to Israel as a foreign resident;
Plans to immigrate to Israel or return to Israel.

Digital asset matters require particular care because the applicable rules and administrative approach may develop over time. Professional analysis should be based on the facts, relevant tax years, and current guidance.

Immigration to Israel or returning to Israel: an opportunity for planning, not an automatic solution

Individuals who immigrate to Israel, return to Israel or maintain a substantial connection with Israel may face complex questions, including:

When Israeli tax residence began;
How income generated before the move should be treated;
How foreign assets should be reported;
What obligations may continue in the country of origin;
How income generated after immigration or return should be treated;
Whether a relevant tax treaty applies;
How Israeli and foreign reporting should be coordinated.

Immigration to Israel or a change in tax residence does not, by itself, erase historical reporting obligations or replace an examination of the source of funds and assets.

In cross-border matters, AUREN Israel can serve as a local professional partner in Israel while coordinating, where appropriate, with professionals in other countries through the AUREN network. The scope of coordination depends on the jurisdictions involved and the specific needs of the client.

What should you avoid doing?

Before taking action, it is important to avoid several common mistakes:

Do not submit partial information before the facts have been reviewed;
Do not transfer funds between accounts merely to create a particular appearance;
Do not close an account or sell an asset before preserving the relevant documentation;
Do not assume that an old asset or a relatively small amount is irrelevant;
Do not rely on an anonymous or abbreviated route that existed under an earlier procedure;
Do not assume that immigration to Israel automatically resolves historical reporting issues.

How can AUREN Israel assist?

AUREN Israel assists individuals, families, business owners, companies and foreign residents in reviewing situations involving uncertainty or potential exposure relating to Israeli or cross-border tax reporting.

Our role may include:

Mapping the relevant facts, income, assets and reporting history;
Reviewing tax residency and cross-border implications;
Assessing available regularization and reporting options;
Coordinating tax, accounting, audit and international aspects;
Supporting the preparation of documents and a practical implementation plan;
Coordinating with professionals in other jurisdictions where required.

The objective is not only to address the existing issue, but also to create a clear picture, reduce uncertainty and establish a reporting and compliance framework that can be maintained over time.

Frequently asked questions

Is there currently a new voluntary disclosure procedure in Israel?

The 2025 Voluntary Disclosure Procedure ended on 31 August 2026. New applications can no longer be submitted under that procedure.

Can income or assets be regularized without a voluntary disclosure procedure?

Possibly. Depending on the facts, it may be possible to consider amended returns, missing filings, settlement of tax liabilities or a structured approach to the Israel Tax Authority. There is no single route and no automatic immunity.

Should I approach the Israel Tax Authority on my own?

In straightforward cases, an individual may be able to take certain steps independently. However, where foreign assets, significant amounts, several tax years, tax residency issues or potential enforcement implications are involved, a professional review should generally be completed before information is submitted or contact is initiated.

Does immigrating to Israel resolve historical tax issues?

Not automatically. Immigration or a return to Israel may create important planning opportunities, but reporting obligations, the source of assets and income, the relevant tax years and the connection with other countries must be examined separately.

Conclusion

The end of the Voluntary Disclosure Procedure is not a reason to ignore an existing reporting issue. It is also not a reason to act without a plan.

Where income, accounts, assets or activity were not properly reported, the first step is to understand the complete picture. The next step is to assess the appropriate tax, accounting and regulatory options.

The solution may involve amended returns, late filings, settlement of tax liabilities, cross-border coordination or a combination of several steps. The appropriate approach depends on the facts and on the timing of the action.

If you have uncertainty regarding income, assets or reporting obligations connected with Israel or another country, it is generally preferable to obtain a structured assessment before waiting for an approach by the authorities or submitting incomplete information.

Contact AUREN Israel to discuss your situation and the available options.

This article is provided for general information only and does not constitute tax advice, legal advice, or a substitute for a review of the individual’s or company’s specific circumstances. Laws, procedures and administrative practices may change. Each case should be assessed based on its facts and the most current official guidance.