International taxation

A global world requires a broad vision and ability to provide both international and local response. Auren’s experts will provide you with a wide range of solutions and peace of mind, by taking care of all taxation issues addressed in Israel and everywhere in the world. We offer Inbound and Outbound Tax Solutions for both our foreign clients operating in Israel and our Israeli clients who have business operations around the world.

Our vast knowledge and experience enable us to assist multinational companies in building an overall international taxation strategy that satisfies the professional and legal requirements of the local law. As well as representation of our clients (a full fiscal representation) in Israel and worldwide; from tax planning, filing reports, estimation and discussions, in addition to representation in reviews versus tax authorities.

Transfer Pricing Study

Internationally deployed organizations are required to disclose transfer pricing research policies.

Global solutions are our expertise, with the benefits of having a supportive professional network of local and international experts.

Transfer pricing research must fit all countries in which business activity is conducted and address the needs and legal requirements of each country.

Our solutions include:

  • Economic Analysis: Analysis for all types of intercompany transactions including tangible, intangible assets and financial transactions.
  • Generating) pre-ruling( agreements: with tax authorities in Israel and in the world. Assist with development, documentation, and reporting accordingly to the new requirements of the OECD and BEPS.

BEPS and OECD regulations:

15 methods have been developed as part of the joint project of the OECD and the G20 on BEPS; to provide governments with tools at the local and international levels to deal with tax planning.

Auren’s international taxation experts follow BEPS’s operating patterns, alongside with the knowledge and experience to provide innovative and efficient tax planning that meets legal and business requirements in each state, and also at the international level.

Double Taxation Prevention Treaty:

A major cornerstone of multinational taxation solutions, these treaties are the foundation of the global world. Auren’s tax experts cross-check the data and benefits of tax treaties between Israel and the target countries, along with examining agreements between different countries that might be included in international business activity and affect the proper course of business operations.

Multinational Agreements (MLI):

The multilateral treaty for sharing and exchanging information encourages companies and private individuals with capital to plan their international business in an innovative and better way.

Our tax experts provide legally and effective tax solutions that are customized to the needs of the business and the capital owner; we are acting to reduce their international tax liability required to the minimum possible. That is thanks to extensive experience resulting from the understanding that all information has always been transparent and accessible to the tax authorities.

Intellectual Property:

The decision on intellectual property registration in a particular country can be critical to the future of business.

Auren’s tax experts take into consideration the state of the organization today, and the future business plans, to formulate an optimal recommendation for intellectual property registration.

Tax deduction for foreign residents:

Foreign residents and foreign organizations, which are operating in Israel, are usually liable for a tax deduction.

Our tax experts will act to reduce or to annulment the deduction according to the tax status that has been determined for facing the tax authorities.

Tax refunds and tax credits between countries:

Refund is a privilege, don’t give up on it. Auren’s tax experts will help you to get tax refunds in Israel and worldwide. If you have paid tax according to the Israeli and international law, our tax experts will assist in providing the required documents and will assist with the entire tax credit process for internationally paid taxes.

Fiscal Representation in Israel

If you are a foreign company or any other business entity, whose taking steps toward the establishment of a business in Israel; we are recommending you to come and meet our professional consultants. A fiscal representative office might be a great solution that we can provide.

Each business that conducts a business activity of any kind in Israel requires by the local law to report and pay taxes to the Israeli tax authorities.

Regardless of the chosen formal structure. Whether it is a company establishment or a registration of a branch in Israel. From the establishment of a registered company, a branch, a related company or a subsidiary. Also, there are local requirements of the Israeli law, which should be complied with when basing and conducting business activity in Israel.

Before starting and conducting any business activity in Israel, it is advisable, either to register a fiscal representative office that functions as a local representative of the foreign business entity or to establish an Israeli company.

A foreign business entity that decides not to establish a local company in Israel must meet the requirements of section 60 of the Value Added Tax (VAT) Law, 1975which requires the appointment of a fiscal representative for a foreign company that conducts its business in Israel.

The representative should be an Israeli resident or a registered corporation in Israel. A foreign company is obligated to report to VAT authorities in Israel within 30 days regarding its representative’s identity for tax purposes.

We are offering our services as your fiscal representatives, to represent your company: submitting tax reports to the tax authorities and managing nonresidents’ funds according to the requirements of the local laws in Israel.

A fiscal representative has personal liability for all tax and legal obligations, to deal with the local authorities in Israel, which are related to the local office operation for the behalf of the foreign company head office located abroad. Legally the local office is under the supervision of the head office of the foreign company. 

Our services include:

  • Representation of foreign companies before Israeli authorities, including income tax, VAT, social security, etc.
  • Primary tax planning before future transactions (“Pre-ruling“)
  • Supervision of the business activity of the foreign entity in Israel, dealing with various local bodies; including business and strategic partners, suppliers, banks, financial institutions, and authorities
  • Assistance in selecting appropriate service providers if needed, such as attorneys, insurance agents, IT systems suppliers, etc.
  • Support in various operational and logistical issues
  • Assistance in relocating personnel to Israel, including employment arrangements, foreign worker status arrangements according to the Trade Law, obtaining special work permits, payroll preparation, etc.
  • Providing auditing, accounting, and financial management services for foreign entities in Israel
  • Executive compensation strategy and options plans which meet the Israeli law requirements, limitations and to profit from its benefits
  • Business support and financial consulting regarding foreign corporations’ worldwide business activities, with emphasis on Israel, including company evaluation, due diligence, strategy and business development assistance in international and Israel transactions, PPA, etc.

Auren Israel represents many foreign companies, which chose to register a fiscal representation through a local company. This local office or branch functions as a foreign company branch in Israel.


Taxation solutions

The world is evolving and changing at a rapid pace, which means that adjustments and changes must also be made in the legislative systems, including the taxation system on the local level in Israel and globally. The rapid pace of change is forcing organizations to develop innovative and creative solutions at a faster rate compared to the development rate in the past.

Our teams of experts at Auren believe in comprehensive and multidisciplinary solutions. Therefore our teams’ efforts focus on providing a variety of complex and integrated tax solutions. Our multidisciplinary business-industrial knowledge enables us, through innovative insights and philosophy, to help your organization excel worldwide.

We are here for you, and we believe that our values are a key factor in our ability to provide our customers with the highest possible added value. We believe in direct communication between our clients to the partners and senior staff, alongside caring, availability, innovation and professional expertise. This differentiation in approach is key to achieving our clients’ goals.

The tax solutions required today for each organization are at two essential levels:

Strategic tax planning: Global and flexible planning, which supports and based on the business plan, goals and objectives. This planning requires constant periodic updating.

Constant support and attention: A treatment that is fast, up-to-date and innovative, which is regularly and is constantly integrated into the company’s ongoing activities and processes.

Among the many solutions, we provide:

Develop a global and flexible tax strategy: A strategy that aligns with the client’s business model and enables future restructuring.

Choosing the structure of the corporation: Examining structural alternatives and assisting in adjustments; choose the optimal corporate structure based on the nature of the organization’s operation and business activities in Israel and abroad.

Fiscal Representation in Israel: Full and broad fiscal representation vis-à-vis tax authorities, state institutions and other authorities in Israel and around everywhere in the world.

Financing of international business activities and investments: Effective counseling, guidance and tax planning.

Corporate structure change and restructuring: Change of corporate structure, restructuring model, and adaptation to international acquisitions.

Overseas income taxation: Non-Israeli sources of income require effective and considerate care to channel them to Israel in the most effective manner.

Issues requiring Double taxation treaties knowledge: The impact of the treaty on tax multiplication and overseas tax benefits includes the implications of the BEPS, OECD, and MLI, as well as multilateral treaties for sharing and exchanging information.

Preparation of tax report for international business entities: Tax reports are diverse as needed for companies, partnerships, and individuals in Israel and in any country where our clients operate internationally.

Representation before the tax authorities

Our clients are a large and cohesive family and as such, we work to ensure that you receive full support vis-à-vis the tax authorities in Israel and worldwide. The mission of Auren’s professional team is to provide you with complete peace of mind and confidence that you are fully and professionally represented before the tax authorities. This will allow you to focus on your business growth. We believe that clients don’t have to deal with tax authorities. Therefore any kind of interaction with the tax authorities, from minor to crucial will be fully and thoroughly handled. We are taking the full responsibility to deal and to communicate with the tax authorities; from joint correspondence, inquiries from tax authorities to audit hearings.

Reports to the tax authorities in Israel and worldwide:

Our international team will handle the necessary adjustments to report in each country where your organization operates and assist in complying with applicable law requirements.

Tax counseling:

Tax counseling begins by building a strategy of optimization of the tax structure for your business and your personal capital; through ongoing consulting for any tax or issue that arises in the ordinary course of business and up to planning an updated annual plan before preparing the annual reports in Israel and worldwide.

Auren’s tax experts will provide a local response for each country as well as a broad view of both private and business international activities.

Voluntary Disclosure:

Disclosure of unreported assets and incomes in Israel and around the world allows you to sleep peacefully at night. The disclosure procedure has become widespread in recent years in Israel and around the world, as a result of the international transparency and information transmitted today regarding the assets and incomes of the majority of the public among tax authorities worldwide and in Israel.

Disclosure can be done in several ways, in Israel and abroad. The international layout of Auren’s experts enables to find a personal, optimal solution for reporting and discovery, utilizing a creative range of solutions. We handle dozens of cases of disclosure every year.

Due to the sensitivity of the subject, we do recommend to set a personal consultation meeting in our office to find out the best process for you.

Tax Benefits and Laws of Encouragement:

Israeli organizations, as well as foreign companies wishing to operate in Israel, can enjoy significant tax benefits offered by the State of Israel.

Auren’s experts will identify the best route for you based on the organization’s goals and business plan.

Israeli organizations operating abroad can also benefit from various tax and state benefits abroad. There are tax benefits programs for exporters provided by the state of Israel, and also other country’s tax benefits programs available. Our international team of experts will handle your case to find the grant program that suits your business. 

The Angels Law for investors:

The “Angels Law” is an alias given to a law section designed to promote knowledge-intensive industries in Israel, through the creation of a tax incentive to encourage the investment of individuals (angels) in start-ups, investments that will help make them stable and well-established companies.

The incentive is given by allowing individuals to invest in shares of Research and Development (R&D), intensive companies as a recognized expense. This law allows the investor to save his first year of the investment taxes, as well as in the years to come.

Auren Israel’s tax experts will assist the company in meeting the requirements and with the reports required to enable investors to receive the tax benefit. We will also assist the investors themselves to implement the right and receiving the benefit.

Technologies Taxation

The technological world is changing rapidly; these changes require flexibility and finding new solutions to the complex challenges and tax issues that arise.

Auren’s tax experts in Israel have developed new and advanced methods that allow synchronization between the tax world and the technological world to provide innovative tax solutions that meet the legal requirements and are customized to the business and organizational needs.

High-tech:

The high-tech world is impacted and needs a quick response to the changes and transformations that apply, reactivity is a powerful tool.

Our taxation solutions help both the company and shareholders at the corporate level; Starting from the stock structure to raising capital, investments, mergers, and dividends.

The essence of the high-tech industry contains many technological services and products that require taxation solutions both structured and integral. From domestic and international apps that have financial implications that raise taxation issues such as payments, withholding, tax liability to the buyer, seller, user and more, through local and international VAT issues to labor law.

E-commerce:

E-commerce taxation is around us in all areas of activity, from products to services, as well as from personal and private commerce to industrial commerce.

The rich experience of Auren Israel’s tax experts will suit every trading platform and any business that includes in E-commerce operations a suitable and unique solution.

E-commerce in its essence combines both local and international taxation issues, which is an advantage for our customers.

Auren’s international team will work to find the best international solution, as well as represent and implement it with the tax authorities in Israel and around the world.

Virtual currencies\ digital currencies:

Issuing a new currency or trading in existing cryptographic currencies creates plenty and intricate tax regulations that are handled in each country differently according to the local tax laws in that country.

Auren’s expert team will provide the appropriate solution to the local reporting in Israel and abroad for the unique credits and deductions for the cryptocurrency trade.

Blockchain:

The blockchain sector is not just reserved for cryptographic currencies, it’s widely used in the trading and the operating mechanisms developing and surrounding us in the emerging markets of the recent years.

From finance, insurance to logistics, and technology. In each of these industries, which the blockchain has entered, there are new taxation issues and reporting issues arise. Auren’s taxation experts have the proficient specific knowledge and ability to provide a variety of customed taxation solutions for advanced technology usage.

Drop-shipping:

Drop-shipping trade characterized by its structure of trade, which includes in most cases three countries: the country in which the director of commerce is located, the manufacturing country, and the country in which the products are being sold.

To meet the legal requirements in all the countries involved in the process, preliminary planning is required, afterward, the reports and tax payments will be fulfilled and completed according to the most efficient and cost-effective taxation strategy set by Auren’s international expert team to execute it for you.

Ruling and pre-ruling

Pre-ruling can provide you peace of mind. The pre-ruling process has the potential of saving you money and uncertainty:

Many organizations and businesses seek to neutralize every element of uncertainty through taxation decisions (pre-ruling decisions have the power to do so).

Preliminary taxation decisions are a powerful apparatus in the world of taxation. Auren Israel has developed a structured methodology for handling and obtaining preliminary taxation agreements with tax authorities so that the taxation decision will serve the needs and goals of the organization.

In this framework, we will develop a detailed and reasoned tax stand; which we will present to the tax authorities, before the submission of the application; we will ensure that the tax authorities are cooperative and supporting our position.

A preliminary consultation process for the client will allow the diagnosis and guidance on the feasibility of submitting a ruling request or other recommendations such as other counseling to achieve the best result for your business needs.

A “taxation decision” is a decision that regards the tax liability, tax results or tax consequences of a business activity carried out by the applicant for a tax decision or due to income, profit, expense or loss.

A tax decision is given by the department of tax decisions of the Israeli Tax Authority. The operation is carried out in most cases after it is getting the approval of the pre-ruling, and in some cases even after its implementation.

Taxation decisions can also be made in other countries, where the organization operates, and where our clients have business operations.

Auren International’s team of experts will assist and submit according to the same unique methodology of success and adaptation of the taxation decision to the business needs.

The tax areas in which a preliminary tax decision can be made in Israel:

  • Ruling in IRS
  • VAT Rolling
  • Ruling for Real Estate Taxation
  • Ruling adjustments due to an inflation  
  • Ruling on Capital Investment benefits
  • Ruling on Capital Investment benefits in the agriculture industry
  • Ruling on the Industry benefits Law (Taxes)
  • Ruling for various specific tax provisions