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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Part 8: Returns, Notices and Information
Chapter I: Preparation and Submission of a Return
Authority to require maintenance of books§
130.
(a)
(1)For the purpose of assessment, the Director may instruct, generally or for a particular category of assessees, the maintenance of account books of income derived from a business or profession, and may prescribe in those instructions rules for the method of maintaining the books, including requiring the assessee to demand from any person with whom the assessee maintains any business relationship to furnish the assessee with that person's personal particulars and to identify themselves; the instructions shall enter into force upon the expiry of three months from the date of their publication in Reshumot (Official Gazette) or at a later date prescribed by the Director, and the Director may do so generally or for a particular category of assessees; however, the repeal of instructions or the prescription of more lenient instructions may enter into force before the expiry of three months from the date of their publication;
(2)The Director may, upon the application of an assessee, authorise a deviation from the instructions applicable to that assessee, on such conditions and for such period as the Director shall prescribe; if the Director rejects the assessee's application, the assessee may appeal, within three months, before a committee established pursuant to section 146 (hereinafter – Books Admissibility Committee);
(3)The Director may, upon the application of an assessee who is the owner of a micro-business as its meaning in section 145a, and after obtaining the opinion of a committee appointed by the Director for that matter, exempt the assessee from the duty of maintaining books if the requirements prescribed by the Director in rules published in Reshumot (Official Gazette) regarding a physical or mental condition or illiteracy, by reason of which the assessee is unable to fulfil the duty of maintaining books, have been satisfied in respect of that assessee; notice of the composition of a committee appointed for the purposes of this paragraph shall be published in Reshumot (Official Gazette);
(4)For the purpose of implementing this Ordinance, the Director may instruct the maintenance of books in respect of the income, expenditure, receipts and payments of a public institution as defined in section 9(2), a professional organisation as defined in section 9(2a), or a non-profit institution as defined in the Value Added Tax Law, 5736-1975 (hereinafter – institution), and may also prescribe in those instructions rules for the method of maintaining the books, including requiring the institution to demand from any person with whom it maintains any relationship to furnish the institution with that person's personal particulars and to identify themselves; the Director may instruct as aforesaid generally or for a particular category of institutions, and the instructions shall commence three months from the date of their publication or at a later date prescribed by the Director; the repeal of such instructions or the prescription of more lenient instructions may take effect less than three months from the date of their publication;
(5)For the purpose of implementing this Ordinance, the Director may instruct a managing company, as defined in the Supervision of Provident Funds Law, to maintain books in respect of the funds deposited in a provident fund under its management.
(b)Where instructions have been given pursuant to subsection (a), the assessing officer may refuse to accept accounts that are not based on account books maintained in accordance with the instructions, if the deviations from the instructions or the deficiencies found in the account books were material for the purpose of determining the income of an assessee, and in the case of an institution – if they were material.
(c)Where the assessing officer has refused to accept accounts as referred to in subsection (b), or has disqualified account books on account of deficiencies as aforesaid found therein, the assessing officer shall send the assessee or the institution notice thereof and shall set out therein the reasons for the decision.
(c1)Decisions of the assessing officer pursuant to subsections (b) and (c) in respect of an institution require the approval of the Director.
(d)
(1)An appeal against a decision of the assessing officer pursuant to subsection (c) may be lodged before the Books Admissibility Committee within 30 days from the date of receipt of the notice;
(2)The period from the date of lodging the appeal pursuant to paragraph (1) until the receipt of the Committee's decision shall not be counted in the periods referred to in sections 145 and 152(c).
(e)Where an appeal as referred to in subsection (d) has been lodged and dismissed, the account books shall be deemed inadmissible for the purpose of an appeal against the assessment.
(f)No order pursuant to section 152(b) that is based on the non-acceptance or disqualification of books as referred to in subsections (b) or (c) shall be issued before notice has been sent to the assessee pursuant to subsection (c) and before the time for lodging an appeal against the decision of the assessing officer has elapsed, and if an appeal has been lodged – before a decision of the Books Admissibility Committee has been given thereon.
(g)The lodging of an appeal pursuant to this section does not replace an objection pursuant to section 150.
(h)Where no appeal as referred to in subsection (d) has been lodged, the decision of the assessing officer pursuant to subsection (c) may be appealed before the District Court together with the appeal pursuant to section 153.
(i)The provisions of subsections (c) to (f) shall also apply to a decision of the Director pursuant to section 147.
(j)Nothing stated in instructions given pursuant to subsection (a) shall be construed as requiring a person to disclose confidential information that was conveyed to that person by reason of the person's profession.
(k)
(1)Where instructions have been given pursuant to subsection (a) and one of the following has occurred, the books shall be deemed inadmissible, unless the assessing officer was satisfied that there was sufficient reason for the act in question:
(a)use of an invoice that was issued without a sale or provision of a service, or in which the stated amount does not reflect the sale price or the price for the provision of the service, as the case may be; for this purpose, "invoice" – as its meaning in instructions given pursuant to this section, and also a tax invoice as its meaning in the Value Added Tax Law;
(b)a return submitted pursuant to section 131 did not include income of a material amount;
(c)in a return submitted pursuant to section 131, a private expense was deducted, or an expense was deducted without a purchase or receipt of service, or the amount of the expense deducted as aforesaid does not reflect the purchase price or the price for the receipt of the service, all in a manner that reduced the taxable income or increased the loss by a material amount;
(2)A person who disputes a decision given pursuant to paragraph (1) may request the assessing officer, within 30 days from the date of receipt of the decision, to reconsider and amend it; if the assessing officer rejects the request to amend the decision, in whole or in part, the decision may be appealed as though it were an order pursuant to section 152(b), provided that the time for lodging the appeal shall be 60 days from the date on which the decision was given, or together with the appeal against the assessments made for that tax year; for the purpose of this paragraph, "assessing officer" – excluding an assistant assessing officer and a chief collector.
Maintenance of books in foreign currency and determination of income accordingly§
130a.
(a)A diamond dealer shall be entitled to maintain in foreign currency the account books that the dealer is required to maintain pursuant to section 130, in respect of the dealer's diamond business, in accordance with rules to be prescribed by the Minister of Finance with the approval of the Finance Committee of the Knesset, which shall include the conditions under which a person who has chosen to maintain books as aforesaid shall be entitled to retract that choice; for this purpose –
"diamond dealer" – a person whose business, or part of whose business, is the processing of diamonds, trade in diamonds or brokerage thereof, and also a controlling shareholder as its meaning in section 32(9) in a company whose business is as aforesaid;
"diamond business" – the processing of diamonds, trade in diamonds or brokerage thereof, and in respect of a diamond dealer who is a controlling shareholder in a company that is a diamond dealer – any transaction affecting the assets, liabilities or capital that the diamond dealer has invested in or received from the said company or from a company that is a diamond dealer, under the dealer's control.
(b)An assessee who has a permanent establishment outside Israel that is not in the Area as defined in section 3a shall maintain in foreign currency the account books that the assessee is required to maintain pursuant to section 130 in respect of income from that establishment, in accordance with rules prescribed by the Minister of Finance with the approval of the Finance Committee of the Knesset.
(c)In addition to that stated in subsections (a) and (b), the following may maintain in foreign currency the account books they are required to maintain pursuant to section 130, in accordance with rules prescribed by the Minister of Finance with the approval of the Finance Committee of the Knesset, which shall include the conditions under which a person who has chosen to maintain books as aforesaid shall be entitled to retract that choice:
(1)a partnership all of whose partners are non-residents and all of whose investments and all loans granted to the partnership are in foreign currency, and which the Director has approved for the purposes of this section;
(2)a foreign investment company as defined in section 53h of the Capital Investment Encouragement Law, 5719-1959;
(3)a company at least 90% of whose income is from the operation of vessels or aircraft in international transport;
(4)a government company, as defined in the Government Companies Law, 5735-1975, or a company all of whose rights are held by such a government company, whose functional currency, as its meaning in generally accepted accounting principles, is the dollar or the euro, and the Director, in consultation with the Director of the Government Companies Authority as its meaning in the said Law, has examined its compliance with the rules prescribed by the Minister of Finance with the approval of the Finance Committee of the Knesset as aforesaid.
(d)The Minister of Finance may, with the approval of the Finance Committee of the Knesset, prescribe in respect of a diamond dealer who has chosen to maintain books as referred to in subsection (a), and in respect of an assessee who has a permanent establishment outside Israel as referred to in subsection (b), and in respect of a company or partnership that has chosen to maintain books as referred to in subsection (c), rules for the determination and calculation of taxable income, and in particular with respect to expenses, income and depreciation, and rules regarding liability to tax and payment of tax and linkage differentials and interest thereon, all having regard to the maintenance of books in foreign currency as aforesaid; rules pursuant to this subsection shall apply notwithstanding anything stated in any law.
Who is required to submit a return§
131.
(a)The following are required to submit a return:
(1)an individual resident of Israel who has attained the age of 18 at the commencement of the tax year; a registered spouse may choose not to include the income of the other spouse, if the other spouse has submitted a separate return of income, or if the registered spouse has attached to that spouse's return a declaration signed by the other spouse that the other spouse will report income separately;
(2)a spouse who is not a registered spouse and who has declared as referred to in paragraph (1) that the spouse will report income separately;
(3)an individual resident of Israel who has not yet attained the age of 18 at the commencement of the tax year, if that individual had in that year taxable income of not less than 7,200 lira or such other amount as the Minister of Finance has prescribed for this purpose;
(4)a non-resident individual who had taxable income in the tax year;
(5)a body of persons that had income in the tax year;
(5a)a person who in the tax year sold a right in real property or performed a transaction in an association, as defined in the Land Taxation Law, that are not exempt from tax under that law, and did not pay land appreciation tax at the maximum rate applicable under the Land Taxation Law on the real appreciation arising from the sale or the transaction, as the case may be;
(5b)in respect of trusts, each of the following:
(1)a trustee in a resident trust or a trustee in a testamentary trust that is deemed to be a resident of Israel pursuant to section 75l(c)(1), provided that the settlor has not chosen to be the person assessable and liable pursuant to the provisions of section 75g(h) or section 75l(e) and that no representative settlor or representative beneficiary has been chosen pursuant to the provisions of section 75f1, as the case may be;
(2)a trustee who had income or an asset in Israel, whether a resident of Israel or not;
(3)a settlor or beneficiary, as the case may be, who has chosen to be the person assessable and liable pursuant to the provisions of section 75g(g) or (h), or section 75l(e) or (f);
(4)a representative settlor or representative beneficiary, as the case may be, who has chosen to be the person assessable and liable pursuant to the provisions of section 75f1;
(5)a beneficiary who received a distribution from a trustee, even if it is not liable to tax in Israel; the provisions of this paragraph shall not apply to a distribution of an asset whose origin is not in Israel to a beneficiary in a non-resident trust, to a beneficiary in a non-resident beneficiary trust or to a beneficiary in a testamentary trust all of whose beneficiaries are non-residents;
(6)a trustee in a resident beneficiary trust to which section 75h1(d)(3) applies;
(7)a beneficiary who is a resident of Israel and has attained the age of 25 years, in respect of being a beneficiary, unless the beneficiary did not know that the beneficiary was a beneficiary, provided that the value of the trust assets at the end of the tax year is not less than NIS 500,000; for this purpose, "trust assets" – including cash, deposits, securities and real property, in Israel or outside Israel; nothing in this sub-paragraph derogates from any other reporting obligation applicable to such a beneficiary pursuant to subsection (a);
any term in this paragraph shall have the meaning assigned to it in section 75c or in section 75f1, as the case may be;
(5c)a controlling shareholder as defined in section 75b, in a foreign professional company, as defined in section 5, or in a controlled foreign company, as defined in section 75b;
(5d)a person who performed a transaction designated pursuant to subsection (g) as a transaction requiring disclosure;
(5e)an individual in respect of whom the presumption set out in paragraph (a)(2) of the definition of "resident of Israel" or "resident" in section 1 is satisfied, and the presumption is rebutted at the individual's contention as referred to in paragraph (a)(3) of that definition – a return detailing only the facts on which the contention is based, to which the individual shall attach the documents supporting the contention, if any; however, nothing in this sub-paragraph derogates from the reporting obligation applicable to an individual pursuant to subsection (a)(4), if the individual had taxable income in the tax year; the provisions of this paragraph shall not apply to the following:
(a)the spouse and children of such an individual;
(b)an individual in respect of whom that which is stated in the concluding part of paragraph (a)(4) of the definition of "resident of Israel" or "resident" in section 1 applies;
(c)a foreign worker as defined in section 48a;
(5f)an individual resident of Israel who transferred, in the course of 12 months, funds outside Israel in a total amount of NIS 500,000 or more (hereinafter – reportable amount); a return pursuant to this paragraph shall be submitted for the year in which the reportable amount, in whole or in part, was first transferred outside Israel and for the year following it;
(6)any person whom the assessing officer has required to do so, even if that person is not required to submit a return pursuant to this subsection.
(a1)Where a return that includes the income of both spouses has been submitted, each of the spouses shall sign the return to confirm the correctness of the declarations relating to that spouse's part.
(b)The return shall set out the income that the person submitting it had in the tax year to which the return relates, as well as all the particulars required for the purposes of this Ordinance with respect to that income, and the following shall be attached thereto –
(1)a balance sheet and profit and loss account – if the return is based on a complete system of accounts according to the double-entry accounting method;
(2)a detailed computation on which the declared income is based – if the return is based on a system of accounts other than as referred to in paragraph (1);
(3)a detailed estimate of the turnover, expenses or profit percentage, or other documents or data on which the declared income is based – if the return is not based on account books.
(b1)The return shall set out every transaction designated pursuant to subsection (g) as a transaction requiring disclosure.
(b1a)The return shall set out disclosure in respect of an opinion as referred to in section 131d and a reportable position as referred to in section 131e.
(b2)
(1)An individual required to submit a return pursuant to subsection (a)(1) to (4), (5a), (5c), (5d) and (6), who has income pursuant to section 2(1), (2) or (8), or a body of persons required to submit a return pursuant to subsection (a)(5), shall submit the return in accordance with the provisions of this section by electronic means, as the Director shall instruct, accompanied by a declaration in the form prescribed by the Director to the effect that the particulars and information furnished in the return are correct and complete, as well as a signed printout of that return (hereinafter – independent electronic return);
(2)An individual or body of persons as referred to in sub-paragraph (1) who has not submitted an independent electronic return shall be deemed, for the purposes of provisions under this Ordinance, as one who has not submitted a return;
(3)Provisions under this Ordinance in respect of a return pursuant to section 131 shall apply to an independent electronic return, unless expressly stated otherwise;
(4)Notwithstanding that stated in paragraph (1), the Minister of Finance may, with the approval of the Finance Committee of the Knesset, prescribe categories of bodies of persons that shall be exempt from the duty of submitting an independent electronic return, in accordance with criteria relating to the nature or scope of their activity, and also categories of individuals who shall be exempt as aforesaid in accordance with criteria relating to economic status, level of income and health condition, as well as for other special reasons, to be prescribed in Regulations.
(c)A report pursuant to subsection (a)(5), other than a return of a partnership, shall be certified by an auditor as its meaning in the Auditors Law, 5715-1955, and coordinated by that auditor for tax purposes, except that in a body of persons that is a co-operative society affiliated with a supervisory union, a supervisory union officer who has been duly registered with the Registrar of Co-operative Societies may also certify the return and coordinate it for tax purposes.
(c1)
(1)In a return as referred to in subsection (a)(5b)(1), (3), (4) or (6), the trustee, settlor, representative settlor, beneficiary or representative beneficiary, as the case may be, shall set out each of the following:
(a)the particulars of all the settlors and all the beneficiaries, the particulars of the trustee and the trust protector if one exists, and the residency of each of them, and if any of them is not an individual – also the particulars of an individual who is a controlling shareholder therein;
(b)the particulars of the assets conveyed to the trustee or whose income has been conveyed to the trustee, as well as the particulars of the income conveyed to the trustee from such assets, and the date of the conveyance of the asset or income as aforesaid;
(c)particulars of the assets distributed and particulars of the income distributed, as well as the date of distribution;
(2)In a return as referred to in subsection (a)(5b)(2), the trustee shall specify each of the following:
(a)particulars of all settlors and all beneficiaries, particulars of the trustee and the trust protector if one exists, and the residency of each of them, and if any of these is not an individual — also the particulars of an individual who is a controlling shareholder thereof;
(b)particulars of the assets in Israel conveyed to the trustee or whose income was conveyed to the trustee, as well as particulars of the income conveyed to the trustee from such assets, and the date of conveyance of the asset or the income as aforesaid;
(c)particulars of the assets in Israel that were distributed and particulars of the income distributed from assets in Israel, as well as the date of distribution;
(3)In this subsection —
"controlling shareholder" — as defined in paragraph (1) or (2) of the definition of "controlling shareholder" in section 135b;
"particulars of the assets" — including the original price, the balance of the original price and the date of acquisition, as defined in section 88, the acquisition value and the date of acquisition as their meaning in Chapter III of the Land Taxation Law and the balance of the acquisition value as defined in section 47 of that Law, as the case may be.
(c2)To a return under subsection (a)(5c) of a controlling shareholder in a foreign professional company, there shall be attached an audited financial report of the foreign professional company, in accordance with generally accepted accounting principles in Israel, and if it is a company that submits a return or is assessed in a reciprocal state, as its meaning in section 196, a report drawn up for tax purposes in accordance with the tax laws of that state.
(c3)In a return as referred to in subsection (a)(5), the particulars of all those who were controlling shareholders in the body of persons during the tax year and the residency of each of them shall be specified; for this purpose, "controlling shareholder" — as defined in section 135b.
(d)The Minister of Finance, with the approval of the Finance Committee of the Knesset, may prescribe rules for obligating a partnership to submit a return certified and reconciled by an auditor for tax purposes.
(e)The Minister of Finance may prescribe by Order the form of the certification and reconciliation as referred to in subsection (c).
(f)A person who did not attach to the return the documents as specified in subsection (b), or whose submitted return was not certified and reconciled as referred to in subsection (c), shall be regarded for the purposes of sections 145(b) and 158a(c) as if they had not submitted a return, unless they submitted the said documents at another time permitted by the assessing officer.
(g)The Minister of Finance, with the approval of the Finance Committee of the Knesset, may prescribe transactions that are subject to reporting, and the manner and scope of reporting; in this subsection, "transaction" — including a deal and a sale, and including where the provisions of the Land Taxation Law apply thereto.
(h)The Minister of Finance, with the approval of the Finance Committee of the Knesset, may prescribe, with respect to a person liable to submit a return regarding particulars of a controlling shareholder as referred to in subsections (c1) and (c3), provisions regarding the identification of a controlling shareholder and provisions regarding registration, documentation, preservation of documents and maintenance of records with respect to the said identification particulars.
Additional Returns§
131a.
The Minister of Finance may prescribe by Regulations additional returns that a body of persons liable to submit a return under section 131(a)(5), or that a resident of Israel liable to submit a return under section 131(a)(5b), shall attach to the return under that section.
Return from an Auditor and an Officer of a Supervisory Union§
131b.
An assessing officer may, if satisfied that there is reasonable cause to do so, require in writing from an auditor, or from an officer of a supervisory union, who has certified a balance sheet or reconciled and certified a reconciliation account for a body of persons under section 131, to furnish to the assessing officer a return on the scope of the audit conducted and its findings, with respect to those particulars specified in the said requirement of the assessing officer.
In this section —
(1)"certified a balance sheet" —
(a)in the case of a company that is not a co-operative society affiliated with a supervisory union — the preparation of a report as specified in section 109 of the Companies Ordinance;
(b)in the case of a co-operative society affiliated with a supervisory union — the conduct of an audit under section 20 of the Co-operative Societies Ordinance;
(2)"assessing officer" — excluding an assistant assessing officer and a chief collector;
(3)"officer of a supervisory union" — as referred to in section 131.
Submission by Electronic Means§
131c.
(a)In this section —
"submission by electronic means" — the submission of a return, document or form by means of an electronic message;
"Electronic Signature Law" — the Electronic Signature Law, 5761-2001;
"electronic message" — as defined in the Electronic Signature Law.
(b)In addition to what is stated in sections 91(d)(1a), 131(b2), 135(1)(a1), 166(b) and 240b(c), the Minister of Finance, with the approval of the Finance Committee of the Knesset, may prescribe that additional returns, documents or forms that are to be submitted to the assessing officer or to the director under this Ordinance, all or some of them, shall be submitted by electronic means, as the sole means of reporting, and may prescribe likewise also with respect to a person upon whom no obligation to submit by electronic means applies but who has elected to do so.
(c)Notwithstanding what is stated in subsection (b), the Minister of Finance, with the approval of the Finance Committee of the Knesset, may prescribe categories of persons liable to report who shall be exempt from the obligation to submit by electronic means.
(d)The director may prescribe rules regarding submission by electronic means, on the following matters:
(1)the identification procedures for the purpose of submission;
(2)the manner of submission;
(3)the extension of the submission deadline;
(4)the forms and electronic messages to be used for the purpose of submission.
(e)Notwithstanding what is stated in section 2(a) of the Electronic Signature Law, a return, document or form submitted by electronic means in accordance with the rules prescribed by the director under this section shall be regarded as if signed.
(f)A return, document or form that was required to be submitted by electronic means and was not submitted in that manner shall be regarded as if not submitted.
Reporting in Respect of an Opinion§
131d.
(a)In this section —
"opinion" — a written opinion, signed by the opinion provider, given, directly or indirectly, to a person and enabling or intended to enable a tax advantage, provided that one of the following conditions is met in relation thereto:
(1)the fee for the opinion, in whole or in part, is contingent on the amount of the tax advantage that will accrue to the recipient of the opinion;
(2)it is a shelf planning scheme;
"tax advantage" — including any of the following:
(1)a discount or relief from tax, deferral of the tax event, reduction of the amount of tax or of the amount of an advance payment, or tax avoidance;
(2)avoidance of an obligation or liability to withhold tax at source or expenses, or to take into account a loss;
(3)deferral of the date of tax payment;
"fee" — an amount of at least NIS 100,000 agreed between the parties to be paid for the opinion in respect of the maximum total tax saving that will accrue to the recipient of the opinion;
"shelf planning scheme" — one of the following:
(1)an opinion that contains mainly uniform content on the same subject, given directly or indirectly by the opinion provider to at least three persons, within a period of two years, subject to the provisions of subsection (g), who are not relatives and between whom no one person exercises control over another, and which does not depend mainly on the particular circumstances of the recipient of the opinion; for this purpose —
"relative" — as defined in paragraphs (1) or (2) of section 88;
"means of control" and "control" — as defined in section 85a;
(2)an opinion that the opinion provider offered to the recipient on the provider's own initiative, and the recipient was bound by an obligation of confidentiality with respect to its content, in whole or in part.
(b)A person who received an opinion shall report thereon in the return that the person is required to submit under sections 131 and 166, filed for the tax year in respect of which the tax advantage is taken into account, in a form to be prescribed by the director, provided that the delivery of the opinion itself to the Tax Authority shall not be required; the said report shall set out the following only:
(1)the very fact of receipt of the opinion;
(2)the transaction or asset dealt with in the opinion;
(3)the type of tax issue affected by the opinion; in this section, "tax issue" — deductions, depreciation, classification of income, classification of expenditure and any other issue to be prescribed by the director.
(c)A person who did not report as referred to in subsection (b) shall be regarded as if the person had not submitted the return under section 131 or 166, as the case may be.
(d)Notwithstanding what is stated in subsection (b), a person shall not be liable to report —
(1)by reason of a shelf planning scheme as referred to in paragraph (1) only of the definition of "shelf planning scheme" in respect of which no notice has been given under subsection (f);
(2)by reason of an opinion given to that person in respect of issues dealt with in assessment, objection or appeal proceedings, provided that the opinion was given during the period in which the assessment, objection or appeal proceedings are taking place, and in respect of that tax year only.
(e)Without derogating from the provisions of subsection (d)(2), where a person received an opinion after submitting the return under section 131 or 166, the person shall report thereon in a form as referred to in subsection (b), within 60 days of the day on which the person received it.
(f)A person who gave an opinion that constitutes a shelf planning scheme under paragraph (1) of the definition of "shelf planning scheme" shall notify the recipient thereof, provided that the recipient is the third person onwards to whom the opinion was given.
(g)
(1)The provisions of this section shall not apply to a public institution as its meaning in section 9(2);
(2)The provisions of this section shall apply only to an individual or a body of persons upon whom the provisions of sub-paragraphs (a) or (b) below apply:
(a)the person's income in the tax year, excluding income as its meaning in section 89, exceeds NIS 3 million;
(b)the person's income as its meaning in section 89, in the tax year, exceeds NIS 1.5 million, provided that the opinion was given in connection with that income.
Taking a Reportable Position§
131e.
(a)In this section —
"tax advantage" — as defined in section 131d;
"reportable position" — a position in respect of which all of the following conditions are met:
(1)it is contrary to a position published by the Tax Authority by the end of the tax year for which the return is filed;
(2)the tax advantage arising therefrom exceeds NIS 5 million in that tax year or NIS 10 million over a period of at most four tax years.
(b)
(1)A position of the Tax Authority as referred to in paragraph (1) of the definition of "reportable position" shall be published in a separate location on the Tax Authority's website, after the Israel Bar Association, the Institute of Certified Public Accountants in Israel and the chamber as defined in the Law Regulating the Practice of Representation by Tax Advisors, 5765-2005, have been given a reasonable opportunity to present their arguments in relation thereto before its publication;
(2)A position of the Tax Authority shall be formulated in clear and comprehensible language;
(3)
(a)the number of positions to be published by the Tax Authority shall not exceed 50 per year; should the Tax Authority wish to publish additional positions in that year, the Minister of Finance shall submit to the Finance Committee of the Knesset for approval the additional number of positions sought as aforesaid;
(b)notwithstanding what is stated in sub-paragraph (a), in the years 2016 and 2017 the Tax Authority shall be entitled to publish 100 positions per year.
(c)A person liable to submit a return under sections 131 and 166 shall detail in the return whether the person has taken a reportable position, as the director shall prescribe in a form.
(d)Notwithstanding what is stated in subsection (c), a person may submit the form referred to in that subsection within 60 days of the date of submission of the return, and if the person has done so, the form shall be regarded as if submitted on the date of submission of the return.
(e)A person who did not report on time and in the manner referred to in subsection (c) or (d) shall be regarded as if the person had not submitted the return under section 131 or 166, as the case may be.
(f)
(1)The provisions of this section shall not apply to a public institution as its meaning in section 9(2);
(2)The provisions of this section shall apply only to an individual or a body of persons upon whom the provisions of sub-paragraphs (a) or (b) below apply:
(a)the person's income in the tax year, excluding income as its meaning in section 89, exceeds NIS 3 million;
(b)the person's income as its meaning in section 89, in the tax year, exceeds NIS 1.5 million.
The Deadline for Submission§
132.
(a)A return under section 131 shall be delivered to the assessing officer no later than 30 April of each year.
(b)Notwithstanding what is stated in subsection (a) —
(1)a person whose return is based on a complete system of accounts, under the double-entry method of accounting, shall deliver the return under that subsection no later than 31 May of each year;
(1a)an individual or a body of persons liable to submit an independent online return shall submit it by 31 May following the tax year for which the return is filed;
(2)a person for whom a special assessment period has been prescribed is required to deliver the said return no later than the end of five months from the day on which that special assessment period ended.
132a.§
(Repealed — תשמ״א־8)
Extension of Deadline§
133.
An assessing officer may, if satisfied that there is sufficient cause for doing so, extend the submission of the return under section 132(a) or (b), as the case may be, to a date to be prescribed, provided that a person who has received such an extension shall submit, by the date referred to in section 132(a) or (b), as the case may be, an estimated return of the said income to be drawn up to the best of the person's estimate.
Notice of Commencement of Occupation or Change Thereof§
134.
A person who in any tax year opened a business or commenced engaging in a profession or vocation, or commenced conducting their business or profession or vocation at an additional place or at a different place, or changed the type of their business or profession or vocation, shall notify the assessing officer within whose jurisdiction the business is situated or the profession or vocation is conducted thereof in writing, no later than the day of the commencement or change as aforesaid.
Power to Exempt from Submission of a Return§
134a.
The Minister of Finance, with the approval of the Finance Committee of the Knesset, may exempt, conditionally or unconditionally, from the obligation to submit a return the following persons:
(1)a person whose main income is employment income, a pension or income on which tax has been paid under section 122;
(2)a person whose income is not from employment, a business or a profession or vocation and did not exceed an amount equal to three times the amount of the credit points under sections 34 and 36;
(3)a non-resident;
(4)a person who received income from which tax was withheld at source in accordance with the law or to which a tax exemption applies, and who, without that income, would have been exempt from the obligation to submit a return;
(5)a trustee, whether a resident of Israel or not, who had in Israel only income exempt from tax or from which the full tax was lawfully withheld, or an asset whose income is exempt from tax.
(6)the owner of a micro-business as defined in section 87b.
134b.§
(Repealed)
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