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OrdinanceTax Law

Income Tax Ordinance [New Version]

פקודת מס הכנסה [נוסח חדש]

Published: 1961-04-25Last amended 2026-06-08✓ Amendment status checked against the Knesset legislation record on 2026-09-04
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Unofficial English translation — for reference only. It may contain errors or omissions and cannot be relied on as a legal text. Only the Hebrew text published in Reshumot is legally binding.More

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Part 7: Tax Rates

Rate of Tax for an Individual§

121.
(a)The tax on the taxable income of an individual in the tax year shall be as follows:
(1)on every new shekel of the first NIS 301,200 — 31%;
(2)on every new shekel from NIS 301,201 to NIS 560,280 — 35%;
(3)on every additional new shekel — 47%.
(b)
(1)Notwithstanding the provisions of subsection (a)(1) and subject to paragraph (2), in respect of taxable income in the tax year from personal exertion and in respect of taxable income in the tax year of an individual who has reached the age of 60, the following rates shall apply:
(a)on every new shekel of the first NIS 74,640 — 10%;
(b)on every new shekel from NIS 74,641 to NIS 107,040 — 14%;
(c)on every new shekel from NIS 107,041 to NIS 228,000 — 20%;
(d)on every new shekel from NIS 228,001 to NIS 301,200 — 31%;
(2)The reduced rates prescribed in paragraph (1) shall not apply to income in respect of which the keeping of account books is required and in respect of which acceptable books were not kept.
121a.§

(Repealed — תשנ״ד)

Additional Tax on High Incomes§

121b.
(a)An individual whose taxable income in the tax year exceeds NIS 640,000 shall be liable to an additional tax on the part of the taxable income exceeding NIS 640,000 at the rate of 3%.
(a1)In addition to what is stated in subsection (a), an individual whose taxable income from capital sources in the tax year exceeds the amount prescribed in that subsection shall be liable to an additional tax on the part of the taxable income from capital sources exceeding the said amount, at the rate of 2%.
(b)The provisions of section 91(d) regarding advance payments shall not apply to income liable to additional tax under subsections (a) or (a1).
(c)The provisions of this section shall apply notwithstanding anything provided in any enactment.
(d)The provisions of section 8(c) shall apply in respect of the incomes prescribed therein, in computing the taxable income for the purposes of this section.
(e)In this section —

"taxable income" — taxable income as defined in section 1 and as its meaning in section 89, excluding an inflationary amount as defined in section 88 and an inflationary amount as defined in section 47 of the Land Taxation Law, and including appreciation as its meaning in the Land Taxation Law; however, in respect of the sale of a right in real property in a residential apartment as defined in the said Law — only if the sale value thereof exceeds NIS 5,385,285 and the sale is not exempt from tax under any law; the said amount shall be adjusted in accordance with the provisions of section 9(c2) of the Land Taxation Law, and for that purpose the basic index referred to in that section shall be the index published on 7 Shevat 5787 (15 January 2027);

"taxable income from a capital source" — taxable income, excluding each of the following:

(1)income under section 2(1) or (2);
(2)income from personal exertion that is not income as referred to in paragraph (1).

Rental of a Residential Apartment§

122.
(a)An individual who had, in the tax year, income from rent from the letting of an apartment used for residential purposes in Israel (hereinafter in this section — rental income) may pay tax thereon at the rate of 10% thereof in lieu of the tax that individual is liable for under section 121, if the rental income is not income from a business as referred to in section 2(1).
(a1)Tax as referred to in subsection (a) shall be paid within 30 days from the end of the tax year in which the individual had rental income, unless the individual paid advance payments in that tax year under section 175.
(b)(Repealed)
(c)Notwithstanding anything provided in any law, an individual who has elected to pay tax as referred to in subsection (a) shall not be entitled to deduct depreciation or any other amortisation in respect of the apartment, or expenses incurred in the production of the rental income, and shall not be entitled to set-off, credit or exemption from the rental income or from the tax applicable thereto; however, for the purpose of computing the capital gains tax applicable on the sale of the apartment, the maximum amount of depreciation or amortisation that could have been deducted under any law, had it not been for this subsection, for the period during which the individual paid tax as referred to in subsection (a), shall be added to the sale value.
(d)(Repealed)
(e)(Repealed)
(f)Notwithstanding the provisions of subsection (c), for the purpose of computing the rental income produced by the individual from the letting of that individual's sole apartment, the individual may deduct from the said income the amount of the preferred rent paid in that year, up to the amount of the rental income in that year or up to the amount of NIS 90,000 per year, whichever is the lower, provided that the payment made, or part thereof, has not been claimed as a deduction in computing the taxable income of the individual or of another person; for the purposes of this section —
(1)"preferred rent" — rent for an apartment in Israel that the payer leased for the payer's own residence, or an annual payment paid for the maintenance of the payer or the payer's spouse residing with the payer in a home for the elderly as defined in section 49m of the Land Taxation Law or in a geriatric hospital as defined in section 29c of the Public Health Ordinance, 1940, in the tax year, provided that the rent or the annual payment, as the case may be, was not paid to a relative as defined in paragraphs (1) or (2) of the definition of "relative" in section 88;
(2)"sole apartment" — as defined in section 9(c1c)(4) of the Land Taxation Law;
(3)A payment made by an individual or income of an individual shall be deemed to include a payment or income, as the case may be, of that individual's spouse residing with the individual or of that individual's child who has not yet reached the age of 18 and who resides with the individual, and an individual and that individual's spouse, and their children who have not yet reached the age of 18, shall be deemed to be one owner; for this purpose, "spouse" — as its meaning in the Land Taxation Law.

Income from Rent Outside Israel§

122a.
(a)An individual who had, in the tax year, income from rent from the letting of real property outside Israel may pay tax thereon at the rate of 15%, in lieu of the tax that individual is liable for under section 121, if the income is not income from a business as referred to in section 2(1).
(b)An individual who has elected to pay tax as referred to in subsection (a) is not entitled to deduct expenses incurred in the production of the rental income, other than depreciation, and is also not entitled to set-off, credit or exemption from the rental income or from the tax applicable thereto, including a credit as referred to in Part 10, Chapter III.
(c)For the purposes of this section, "real property" — includes part thereof.
123.§

(Repealed — תשל״ה־2)

Rate of Tax on Key Money and Premiums§

124.

Notwithstanding the provisions of sections 121, 126 and 127, the tax on income from key money or from premiums derived from a homestead shall not exceed 35%, if the taxpayer paid the assessing officer tax on such income at the said rate within 30 days from the date of receipt thereof, and if the taxpayer reports income on an accrual basis — at the time prescribed in section 132 for the submission of the return or within 30 days from the date of receipt thereof, whichever is the earlier.

Rate of Tax on the Sale of Rights to Which the Tenant Protection Law Applies§

124a.
(a)In this section —

"the determining date" — 21 Heshvan 5762 (7 November 2001);

"the determining period" — the period from the determining date to the end of tax year 2003.

(b)Notwithstanding the provisions of section 121, a tenant who holds on the determining date an asset to which the Tenant Protection Law applies, and who sells during the determining period the full extent of that tenant's rights in the asset to the holder of the right in that asset, shall be liable to tax on the real capital gain at rates not exceeding the following:
(1)on a sale during the period between the determining date and the end of tax year 2002 — 15%;
(2)on a sale in tax year 2003 — 20%;

provided that after the sale the Tenant Protection Law ceases to apply to that asset.

Rate of Tax on Income from Gambling, Lotteries or Prizes§

124b.

Notwithstanding the provisions of section 121, the rate of tax on income from gambling, lotteries or prize-bearing activities, under section 2a, shall be 35%, without entitlement to any exemption, discount, deduction, credit or set-off whatsoever, other than an exemption under section 9(28) or a deduction under section 17(11).

Rate of Tax on Transfer to a Former Spouse of a Member§

124c.

Notwithstanding the provisions of section 121, the rate of tax on income under section 3(h7)(1) shall be at the rate referred to in section 121(b)(1)(c), without entitlement to any exemption, discount, deduction, credit or set-off whatsoever, other than an exemption under section 9(17a).

Tax rate on the sale of a patent, etc.§

125.

Notwithstanding the provisions of section 121, the rate of tax on income received from the sale of a patent, design or model by the inventor, or from the sale of a copyright by the author, where the invention or creation was outside the scope of their regular occupation, shall not exceed 40%.

Tax on income after death§

125a.

Notwithstanding the provisions of section 121, the rate of tax on the income of a person to which section 3(f) applies and on employment income of a person, received after their death, shall not exceed 40%; for this purpose, "employment income" — includes that part of a grant received on account of death that is not exempt under section 9(7a).

Tax rate on dividend§

125b.

Notwithstanding the provisions of sections 121 and 126, the rate of tax on income from a dividend shall be as follows:

(1)a dividend held by an individual — 25%;
(2)notwithstanding paragraph (1), a dividend held by an individual who, at the time of receipt of the dividend or at any time during the twelve months preceding it, was a substantial shareholder as defined in section 88 in a body of persons that paid the dividend — 30%;
(3)a dividend held by a family company — 25%, however if the taxpayer within the meaning of section 64a was a substantial shareholder, directly or indirectly, in the company that paid the dividend — 30%;
(4)a dividend that is not tax-exempt held by a public institution or by a provident fund as defined in section 9(2) — 25%;
(5)a dividend held by a body of persons that is a foreign resident — 25%, however if the body of persons was, at the time of receipt of the dividend or at any time during the 12 months preceding it, a substantial shareholder as defined in section 88 — 30%.

Tax rate and tax exemption on profits of an individual from a trust fund§

125b1.
(a)Profits distributed by the manager of a liable trust fund to a unit holder who is an individual, where the income does not constitute, in that individual's hands, income from a business or vocation, are exempt from tax.
(b)Profits distributed by the manager of an exempt trust fund to a unit holder who is an individual, where the income does not constitute, in that individual's hands, income from a business or vocation, are liable to tax at a rate of 25%.
(c)Every term in this section shall have the meaning ascribed to it in Part 5.

Tax rate on income from interest and discount charges§

125c.
(a)In this section —

"substantial shareholder" — as defined in section 88;

"index" — the consumer price index as most recently published by the Central Bureau of Statistics before the day in question, and in respect of an asset whose value is linked to a foreign currency or which is denominated in a foreign currency — the rate of that currency;

"interest" — including discount charges.

(b)An individual is liable to tax on income from interest at a rate not exceeding 25%, and such income shall be treated as the highest tier in the scale of that individual's taxable income.
(c)
(1)Notwithstanding the provisions of subsection (b), where interest was paid on an asset that is not linked to the index, or that is partially linked to the rate of increase of the index, in whole or in part, or that is not linked to the index until redemption or repayment, the individual's income from interest shall be liable to tax at a rate of 15%;
(2)The Minister of Finance may, by Order, alter the rate of tax prescribed in paragraph (1) in accordance with changes in the index.
(d)Notwithstanding the provisions of subsections (b) and (c), an individual is liable to tax on income from interest at the rate prescribed in section 121, if any one of the following applies:
(1)the interest is income under section 2(1), or it is recorded in that individual's books of account, or it is required to be so recorded;
(2)the individual has claimed a deduction for interest expenses and linkage differentials in respect of the asset on which the interest is paid;
(3)the individual is a substantial shareholder in the body of persons that paid the interest;
(4)the individual is an employee of the body of persons that paid the interest, or provides it with services or sells it products, or has other special relations with it, unless it is proved to the satisfaction of the assessing officer that the rate of interest was determined in good faith and was not influenced by the existence of such relations between the individual and the body of persons;
(5)the interest was paid from a training fund before the periods referred to in section 9(16a) or (16b) have elapsed, or was paid from a provident fund for severance pay and the provisions of section 3(d) apply to it;
(6)another condition prescribed by the Minister of Finance, with the approval of the Finance Committee of the Knesset, is met.
(e)The provisions of this section shall not apply to monies paid from a provident fund that is not a provident fund for severance pay or that is not a training fund, nor shall they apply to monies paid from a provident fund for severance pay that are liable to tax under the provisions of section 87; however, the provisions of this section shall apply to interest and other profits that are treated as income from interest under the provisions of section 3(h4)(3).

Deduction from interest§

125d.
(a)In this section —

"the determining date" — the 27th day of Tevet 5763 (1 January 2003);

"the preferred ceiling" — an amount of NIS 48,000 per year;

"interest" — interest paid on a deposit with a banking corporation or on a savings plan.

(b)An individual whose income and the income of their spouse in the tax year did not exceed the preferred ceiling is entitled to a deduction of NIS 7,920 (in this section — the permitted deduction) from their taxable income from interest, but not more than their total income from interest; however, if the income of the individual and their spouse in the tax year exceeded the preferred ceiling, the individual shall be entitled to an adjusted deduction; for this purpose, "adjusted deduction" — the permitted deduction, after deducting therefrom the amount by which the taxable income in the tax year of the individual and their spouse exceeded the preferred ceiling.
(c)
(1)An individual who, in the tax year, reached or whose spouse reached the mandatory retirement age within the meaning of the Retirement Age Law, 5764-2004 (in this subsection — mandatory retirement age), and who, at the determining date, one of them had reached the age of 55, is entitled to a deduction of NIS 13,000 from their income from interest, but not more than their total income from interest;
(2)An individual who, in the tax year, both the individual and their spouse reached the mandatory retirement age, and at the determining date both of them had reached the age of 55, is entitled, in lieu of the deduction referred to in paragraph (1), to a deduction of NIS 16,000 from their income from interest, but not more than their total income from interest.

Preferred interest§

125e.
(a)In this section —

"qualifying interest" — the lower of the following:

(1)the income of an individual and their spouse from interest as defined in section 125d(a) (in this section — interest);
(2)income from interest in the amount of the difference between the sum stated in the definition of "qualifying annuity" in section 9a multiplied by 12, and the taxable income of the individual or their spouse, whichever is higher; for this purpose, "taxable income" — including income exempt under sections 9a and 9b and excluding income from interest, income from the lease of a residential apartment that is exempt from tax, capital gain, and appreciation as defined in the Land Taxation Law.
(b)35% of qualifying interest is exempt from tax in the hands of the following:
(1)an individual who has reached retirement age;
(2)an individual if either the individual or their spouse has reached retirement age;

and in all cases, if they had reached the age of 55 at the determining date.

Restriction§

125f.

Deductions under section 125d and a tax exemption under section 125e shall be granted to only one of the spouses.

Corporate tax§

126.
(a)On the taxable income of a body of persons there shall be imposed a tax to be called "corporate tax", at a rate of 23%.
(b)In computing the taxable income under subsection (a), income from a distribution of profits or from a dividend originating from income produced or accrued in Israel, received directly or indirectly from another body of persons liable to corporate tax, shall not be included, nor shall income for which a special tax rate has been prescribed be included.
(c)In computing the taxable income under subsection (a), the taxable income of a body of persons from a dividend originating from income produced or accrued outside Israel, as well as from a dividend originating outside Israel, shall be included; however, if, at the request of the assessed company or pursuant to a treaty for the prevention of double taxation, the foreign taxes imposed on such dividend and on the income from which the dividend was distributed are to be taken into account, the income from the dividend shall be treated as income in the amount of the grossed-up dividend;

In this section —

"the grossed-up dividend" — the amount of income from a dividend plus tax paid on the income from which the dividend was distributed;

"the assessed company" — a company that received a dividend from another company in which it holds 25% or more of the means of control (hereinafter in this section — the other company);

"the income from which the dividend was distributed" — including income originating from a company held directly by the other company at a rate of at least 50%;

"means of control" — as defined in section 88.

(d)In computing the tax applicable to the income from a dividend as referred to in subsection (c), a credit against the tax shall be given in the amount of the corporate tax with which the body of persons distributing the dividend was charged on the income from which the profits or dividend referred to in subsection (a) were paid.
(e)The amount of the credit referred to in subsection (d) and in Part 10 Chapter III shall not exceed the tax applicable to the income from a dividend as referred to in subsection (c), and the provisions of section 205a shall not apply.
(f)Where a body of persons received a dividend and the income therefrom was offset against a loss, and thereafter the body of persons distributed the dividend to its shareholders, the body of persons shall be deemed, for the purposes of subsection (c), to have paid corporate tax at the rate prescribed in subsection (a) in respect of the dividend.

Tax benefit on income from a dividend originating outside Israel — temporary provision for the 2009 tax year§

126a.
(a)In this section —

"controlling shareholder" — as defined in section 3(i);

"income from a dividend", of a company — the taxable income of a company from a dividend originating outside Israel, paid to it by a foreign resident body of persons and received by it in Israel in the 2009 tax year, excluding income as aforesaid from a dividend originating from profits that, had they not been distributed to the company or to another body of persons in the same chain of companies as defined in section 75b(a)(14), would have been undistributed profits as defined in section 75b(a)(12), provided that if the company is a controlling shareholder in the body of persons paying the dividend, the following amounts shall be deducted from the said income:

(1)the amount of a loan given by the company to the body of persons paying the dividend or to a relative thereof during the period from the 4th day of Kislev 5769 (1 December 2008) until the 24th day of Tevet 5771 (31 December 2010) (in this definition — the determining period), which has not been repaid during the determining period;
(2)the amount of a guarantee given by the company to the body of persons paying the dividend or to a relative thereof in respect of a loan taken by the body of persons during the determining period, provided that the guarantee was called upon during that period;
(3)the amount paid by the company during the determining period for the purchase of securities of the body of persons paying the dividend or of a relative thereof;

"relative" — as defined in item (3) of the definition of "relative" in section 88;

"use in Israel" — use that is one of the following by a person, excluding payment, directly or indirectly, to an individual who is a controlling shareholder in the company receiving the dividend:

(1)payment to an Israeli resident for services rendered in Israel or for work performed in Israel;
(2)payment for the purchase or lease of assets whose use will be in Israel, as well as payments to an Israeli resident for the purchase or lease of assets; for this purpose, "asset" — excluding a security as defined in section 88;
(3)payment for the improvement or maintenance of assets in Israel;
(4)investment in research and development in Israel;
(5)repayment of a debt to an Israeli resident, and if the repayment of the debt is to a related body of persons — on condition that that body of persons makes use in Israel of the debt repayment monies;
(6)payment of interest, discount charges or linkage differentials on a bond traded on a stock exchange in Israel, as well as the purchase by the company receiving the dividend of such a bond issued by it;
(7)the deposit of a deposit in Israel with a banking corporation that is an Israeli resident, for a period of at least one year (in this definition — the deposit period), or the purchase of securities traded on a stock exchange in Israel and holding them for a period of at least one year (in this definition — the holding period); for this purpose —
(a)a security shall be treated as if it had been held throughout the entire holding period even if it was sold before the end of that period, if with the entire proceeds of the sale another security traded on a stock exchange in Israel was purchased and held for the remainder of the holding period;
(b)where a certain sum was deposited in a deposit as referred to in this paragraph for a period shorter than the deposit period and securities as referred to in this paragraph were purchased and held, in that same sum, for a period shorter than the holding period, the said sum shall be treated as having been used in Israel under this paragraph if the combined period of the deposit and the holding is at least one year;
(8)payment of a dividend to an Israeli resident company, provided that that company makes use in Israel of such dividend.
(b)Notwithstanding the provisions under this Ordinance, on income from a dividend of a company in which use in Israel was made during the 2009 tax year, or within one year from the date of actual receipt of the dividend, whichever is later, corporate tax shall be imposed at a rate of 5%, at the request of the company, provided that the company that received the dividend is not a house company within the meaning of section 64, a family company within the meaning of section 64a, or a transparent company as defined in section 64a1.
(c)The provisions of section 126 shall apply to the part of the dividend received by the company as referred to in subsection (b) in which use in Israel was not made.
(d)Notwithstanding the provisions under this Ordinance, where a company has requested that corporate tax be imposed on it under this section on its income from a dividend, a credit shall be given against the said tax in respect of tax withheld at source from that income, provided that it shall not exceed the amount of tax under this section, and no credit shall be given against it for foreign taxes not directly imposed, as defined in section 203(c).
(e)The provisions of section 205a shall not apply to foreign taxes, as defined in section 199, paid on income from a dividend charged to corporate tax under this section.
(f)Where a company that has requested that corporate tax be imposed on it under this section proves that it made use in Israel during one of the periods referred to in subsection (b) of any amount, it shall be presumed that the use in Israel of that amount was made out of its income from a dividend, even if that income was received by the company after it made such use.
(g)For the purposes of sub-paragraph (b) of the definition of "controlled foreign company" in section 75b(a)(1), income received by a foreign resident body of persons in the 2009 tax year that was distributed as a dividend to an Israeli resident company in that tax year shall not be taken into account, if the income from that dividend was charged to corporate tax under this section.
127.§

(Repealed)

128.§

(Repealed — תש״ן־6)

Exemption of certain co-operative societies from corporate tax§

129.
(a)A co-operative society whose business is conducted with its members only, or whose business with a person who is not a member thereof is of negligible scope or merely incidental, and the majority of whose said business is the marketing or processing of the agricultural produce of its members, shall be liable to tax at a rate of 20% on that part of its taxable income arising from any of the following:
(1)the marketing or processing of the agricultural produce of its members;
(2)the supply of agricultural inputs and equipment to its members;
(3)its income from agriculture, provided that more than 90% of its members' income from agriculture originates from the marketing of agricultural produce through it;

the amount to which the reduced tax rate shall apply shall not exceed 3% of its business turnover in that year, but the Minister of Finance may, by Order, with the approval of the Finance Committee of the Knesset, increase the said rate.

(b)A co-operative society that has distributed or returned to its members, directly or indirectly, profits on which it paid reduced tax by virtue of the provisions of subsection (a), shall be liable to pay the amount of tax at the reduced rate as aforesaid within 30 days from the date of distribution or return.
(c)In this section —
(1)"co-operative society" — a co-operative society whose members are co-operative societies or individuals, 51% of whose members each have the majority of their income from agriculture, provided that the number of members shall not be less than —
(a)40, if the members are individuals only;
(b)5 co-operative societies whose total number of members as aforesaid is at least 200, if the members are co-operative societies only;
(c)30 individuals and 5 co-operative societies, if the members are both individuals and co-operative societies;
(2)"member" — includes a candidate for membership whose period of candidacy has not yet exceeded one year.
129a.§

(Repealed — תש״ן־2)

Income from real property and foreign securities held by a provident fund§

129b.
(a)Notwithstanding the provisions of section 126, the taxable income of a provident fund from the business of leasing buildings that it constructed itself or through others and whose construction commenced in the 1991 tax year or thereafter shall be liable to tax at a rate of 20%.
(b)(Repealed)
(b1)(Repealed)
(c)(Repealed)
(d)(Repealed)

Income of a trust fund§

129c.
(a)Notwithstanding the provisions of section 126 —
(1)the income and profits of an exempt trust fund are exempt from tax;
(2)on the taxable income of a liable trust fund, the tax rates that would have applied to profits or income as aforesaid had they been received by an individual in whose hands the income is not income from a business or vocation shall apply, unless expressly provided otherwise; where no special tax rate has been prescribed for the income, the income shall be liable to tax at the maximum rate prescribed in section 121;
(3)(Repealed)
(4)in computing the income and profits of a trust fund, interest expenses or linkage differentials shall not be allowed as a deduction;
(5)the Minister of Finance, with the approval of the Finance Committee of the Knesset, may prescribe in respect of the income of a liable trust fund any of the following:
(a)(Repealed)
(b)monthly advance payments in respect of its income in lieu of the advance payments prescribed under this Ordinance; the provisions of sections 177, 180 and 190 shall apply to an advance payment so prescribed, as the case may be;
(c)special provisions regarding tax exemption or a special tax rate, for certain income of a liable trust fund intended for unit holders who are foreign residents, in accordance with the tax rate that would have applied to the income had it been received by foreign residents;
(d)the method of computing the linkage or the inflationary amount in accordance with the investments or assets of the trust fund.
(b)In this section, "trust fund", "exempt trust fund" and "liable trust fund" — as defined in section 88.

Special provision regarding the set-off of losses in a liable trust fund§

129d.

A capital loss from foreign securities incurred by a liable trust fund up to and including the 26th day of Tevet 5763 (31 December 2002) (in this section — the accumulated loss) shall be carried forward to subsequent years, one after another, for the purpose of set-off against capital gain from the sale of foreign securities, provided that in each of the 2003 and 2004 tax years no loss exceeding 40% of the accumulated loss shall be permitted to be set off; however, if in the 2003 tax year an accumulated loss of less than 40% of the accumulated loss was set off, there shall also be permitted to be set off in the 2004 tax year the accumulated loss differential; for the purposes of this section, "the accumulated loss differential" — an amount equal to 40% of the accumulated loss, less the amount of the accumulated loss set off in the 2003 tax year.

Power of the Minister of Finance regarding the taxation of savings plans§

129e.
(a)The Minister of Finance, with the approval of the Finance Committee of the Knesset, may prescribe the rate of tax to be paid by a banking corporation or an insurance company on certain income from monies deposited in a savings plan, attributed to the saver pursuant to the terms of the savings plan, provided that the tax rate prescribed shall not exceed the difference between the tax rate that would have applied to that income had it been received by an individual in whose hands the income is not income from a business or vocation, and 15%; and the Minister may also prescribe a restriction on the deduction of an expense, a provision, or the set-off of a loss against that income, all subject to such conditions as the Minister has prescribed.
(b)Tax as referred to in this section shall be deducted from the income attributed to the saver pursuant to the savings plan, and the banking corporation or insurance company, as the case may be, shall not be entitled to any deduction, credit or set-off in respect of such tax.
(c)Notwithstanding any law, a saver in a savings plan as referred to in this section is not entitled to a tax refund or a credit in respect of tax paid by the banking corporation or insurance company, as the case may be.

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