Luxembourg ratifies tax treaty with Israel

The treaty enables Israel to collect taxes from companies using Luxembourg as a tax shelter.

“The tax treaty with Israel ratified by the Luxembourg authorities will immediately lead to Israel collecting hundreds of millions of shekels in taxes from companies that use Luxembourg as a tax shelter, says former Income Tax commissioner Adv. Tali Yaron-Aldar, now at the Cohen, Cohen, Yaron-Eldar & Co. law firm.

Yaron-Eldar said the tax treaty would dramatically change tax planning by Israeli customers and individuals who have multinational investments held through Luxembourg. Cohen, Cohen, Yaron-Eldar international tax practice head Henriette Fuchs-Grootscholten believes that at least 200 Israeli companies and financial institutions using Luxembourg as a tax shelter would be affected by the treaty, which comes into effect immediately.

Yaron-Eldar says many Israelis chose Luxembourg as a tax shelter because foreign companies pay 20% capital gains tax, compared with the 25% rate in Israel for foreign-controlled companies, under the 2003 tax reform. Under treaties to prevent double taxation, until now Israeli companies paid only the 5% difference in the tax rates.

Another advantage for companies in Luxembourg is that taxes are levied only if shareholders withdraw dividends, whereas under Israeli law, tax is levied on a company’s capital gains, regardless whether or not it distributes a dividend. Luxembourg also does not levy a tax if a company invests its profits in the company. Israeli companies have therefore used Luxembourg as a pipeline, setting up companies through which they made investments worldwide.

Published by Globes [online], Israel business news - www.globes.co.il - on April 2, 2006

© Copyright of Globes Publisher Itonut (1983) Ltd. 2006

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