Leon Harris

Press Conference of US President Trump and Prime Minister Netanyahu revealed what a country has to do to dodge the US tariff bullet. The medicine might be bitter.  On April 7, 2025 US President Trump and Israeli Prime Minister Netanyahu announced at a press conference in the White House that Israel will produce a plan […]

Investment and Doing Business in the Czech Republic Brief Introduction of the Czech Republic The Czech Republic (CR) is a landlocked country in Central Europe. It has about 10.8 million inhabitants. After the fall of the communist regime in 1989, a period of major economic changes begun. It was necessary to reconstruct the economic system […]

On January 1, 2025, the standard rate of VAT in Israel increases from 17% to 18%. The Israeli Tax Authority (ITA) issued instructions on how the rate rise will be implemented for different types of transactions. (Interpretative Instructions 01/2025, dated Dec 5, 2024). Broadly, if the taxable event is after the end of 2024, the […]

EXECUTIVE SUMMARY: Structuring an M&A deal can be challenging both to the seller making an exit and the purchaser planning due diligence.Consider among other things, the following:(1) Stock (shares) versus asset deal(2) Tax and legal implications(3) Finance(4) Etc We are experienced M&A consultants. Can we help you? Need more info? [email protected]://mergeacq.com/ ARTICLE: When planning an […]

The Israeli tax break rules are being tightened up for new Employee Share (=Stock) Ownership Plans (ESOPs) commencing January 1, 2025. This will be important for many Israeli hitech and other companies, and their employees.   (Regulations Number 11461 of Sep 17, 2024) Current ESOP Tax Breaks in Israel Section 102 of the Israeli Income Tax […]

Back on July 1, 2021, the OECD and G20 announced that 130 countries, led by the USA, had joined the Two Pillar tax reform package aimed to “ensure that multinational enterprises pay a fair share of tax wherever they operate”. That number now stands at 147 countries. The OECD hopes to re-allocate a quarter of […]

Comprehensive EU VAT rules apply to cross-border business-to-consumer (B2C) e-commerce supplies of goods and services, both within the EU and from outside it. If you sell anything to EU consumers via the internet, read on. The general principle is that all supplies to EU residents are now subject to EU VAT, with no de minimis […]

The EU issued tough rules in 2015 and 2021 for non-EU businesses that do e-commerce with consumers in the EU. The EU is an important marketplace with 27 member countries. These rules apply the destination principle – EU VAT is collectible at the VAT rate in the customer’s country. The EU rules distinguish between B2B […]

Lisa Minelli told that money makes the world go round, but she didn’t say how. . People go into business to make money. One method to help them do so is the accelerator (or incubator). What is an accelerator? An accelerator is a facility in which financial and business experts provide advice, administrative support and […]

Who sets the fiscal policy in most Western countries? If you said the Finance Ministry in each country, go to the back of the class. And if you said the Central Bank in each country, take some extra classes. In practice, there is a new sheriff in town, in over 140 countries…the OECD. It has […]

Multinational groups, large and small, are now overhauling their international tax planning from top to bottom, due to BEPS, hopefully without getting into the Panama Papers. What is BEPS? On October 5, 2015 the OECD published a comprehensive package of measures aimed at BEPS – Base Erosion Profit Shifting. Countries around the world are starting […]

When Paul Simon sang the hit Slip Slidin’ away, he had in mind a girl called Delores. When the OECD comments on intangible assets sliding away, they have in mind Dollars and Euros – in the OECD Transfer Pricing Guidelines, and Guidance for Tax Administrations of the Approach to Hard-to-Value Intangibles (HTVI). The guidance clarifies […]

We all know that the Boston tea partygoers believed they should not pay taxation without representation. But now that democracy has arrived in the USA and most other countries, what (if anything) motivates us to pay taxes? The OECD refers to this motivation to pay tax as “tax morale”. They presumably mean tax morality.  A […]

SUMMARY: In any M&A deal, don’t under-estimate the importance of the initial Letter of Intent (LOI).Consider, among other things, the following:(1) The price(2) The deal structure(3) The payment milestones (4) Etc. Read on. This is Article is part of a series. We are experienced M&A consultants. Can we help you? Need more info? [email protected]://mergeacq.com/ ARTICLE: […]

If a company were to place a server on the Moon and use it to generate a commercial profit, would it be taxable? Are worldwide taxation systems in many countries space-wide too? The same question arises with regard to the territories not recognized as countries such as the high seas, the Arctic, Antarctic, Native “Indian” […]

On October 13, 2021 the G20 Finance Ministers endorsed the latest OECD Two Pillar tax package, saying it will “establish a more stable and fairer international tax system”.  But will it? The package now is supported by 147 countries representing over 90% of global GDP. Will your group’s taxes take off? Or will you outfox the OECD? […]

The world is experiencing turbulent times, but some have turned adversity to advantage. For example, some buy widgets from China and sell them to an affluent market such as North America. They use a platform like Amazon to sell and ship stored goods and a payment service like PayPal.  Others provide software as a service […]

It’s getting harder and harder to do business with the EU On July 1st, 2021, new EU VAT rules began to apply to e-commerce that target online platforms and B2C imports of all types and sizes.  Moreover, the EU is now implementing broad new rules for disclosing cross-border arrangements if certain tax-dodging “hallmarks” exist, due […]

Below are some case studies illustrating some of the e-commerce tax complexities of our time. Case study 1 The Great Widget Group, headquartered in the UK, has global revenues of EUR 100m and global profits of EUR80m. It uses a Cayman Islands offshore subsidiary company to buy cheap widgets from China and sell them onwards […]

We’re protected from digital taxes and other fallacies… The new e-commerce tax landscape is getting more cluttered all the time. It can affect most businesses that use the internet. Here is a discussion about a few tax fallacies. Not really. The VAT rules in the EU and other countries target B2C businesses of any size. […]

Tax is not only costly, it is complex. Here are the main areas of complexity a business should plan for internationally and in Israel. International taxation for businesses shows no sign of getting easier, only more complex. Why is that? An illuminating survey was recently published, the Global MC Tax Complexity Survey with discusses the […]

The Pandora Papers expose offshore secrets in a less-than-flattering way. It is best to arrange your all your affairs appropriately. Here’s how.  The International Consortium of Investigative Journalists (ICIJ) published on October 3, 2021 some spicey tales of offshore happenings by famous people in the Pandora Papers. This follows earlier scoops in the Panama Papers. […]

The EU Court of Justice issued a VAT judgment that not only takes a last blast at Britain, it also causes collateral tax damage to US and other non-EU online platforms if they supply services to EU or UK consumers. The case concerns Fenix International (CJEU C-695/20 of February 28, 2023). US and other e-commerce […]

On September 27, 2024, the credit rating agency Moody’s announced it has  downgraded Government of Israel’s long-term local and foreign-currency issuer ratings to Baa1 from A2. And the outlook remains negative (See https://www.jpost.com/breaking-news/article-822128). Given that Israel is at war, is this any surprise? Yes it is, because some of Israel’s borrowings are backed by the US […]

G20 Finance Ministers announced a plan in Rio De Janeiro on July 27, 2024 to help governments around the world improve the state of their finances. Some of it depends on taxing ultra wealthy individuals. It is not quite a Robin Hood plan, because Robin Hood robbed the rich to give to the poor, not […]

Cost plus may no longer be acceptable in Israel for marketing aimed at specific clients, perhaps other cases too.

The Israeli Tax Authority must refund tax wrongly collected on some Israeli homes sold 2007-2023. Time limits apply to claiming tax refunds….

Digital donations become mandatory in Israel from 2025. What does this mean?

Israel moved onto a mandatory system of e-invoicing, known as “Israeli Invoices”, on May 5, 2024.

The OECD has issued rules to help distributors fix a standard taxable profit margin in around 145 countries….

How do you buy or sell a company at a good price. What else matters?

Governments are starting to tax the cloud. What should e-commerce operators plan for?

The Supreme Court said an Article in the US-Israel Treaty didn’t say what it seemed to say….

From 2026 new Olim will need to report exempt income and prepare for questions.

Stay up to date. Learn from other M&A deal..

As more governments collect more taxes thanks to the OECD, will there be any tax justice? Or will each country apply its own rules?

The tax treatment of meals at work can be hard to digest….

The Israeli Supreme Court ruled a meat dealer was also in the real estate business…

What is a hitech SAFE? Why is it needed and what are the Israeli tax implications?

If you buy the shares of an Israeli company and then proceed to strip out the intellectual property, Israeli tax may be due on both the share deal and the IP stripped out…..

The pros and cons of asking the Israeli Tax Authority to talk to a foreign tax administration.

The Israeli VAT rate is set to rise 1% to 18% in 2025. Electric cars may be assessed to a per-kilometer tax starting 2026.

The Israeli Supreme Court recognized a deemed interest expense when no expense was claimed, presumably to make withholding tax payable on the deemed interest.

Summary – give appreciated assets to the right charity.