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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The Hebrew text as published in Reshumot (ספר החוקים) and on the Knesset website is the sole authoritative and legally binding version. In any discrepancy, the Hebrew text prevails.
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Section D: Enforcement of Payment
Assessing officer may enforce payment§
193.
(a)Any amount that a person is liable to pay under this Ordinance may be enforced for payment by the assessing officer in accordance with the provisions set out below, or under the Tax (Collection) Ordinance, and the provisions of that Ordinance, except section 12 thereof, shall apply to the collection of any such amount as if it were a tax as its meaning in that Ordinance; however, if the assessing officer is not the district governor, the assessing officer shall send to the district governor of the district in which the taxpayer resides, or in which he carries on his business, a certificate signed by the assessing officer specifying the amount of the arrears due from the taxpayer, and the district governor, upon receiving the certificate, shall enforce payment in accordance with the provisions of the Tax (Collection) Ordinance applicable to the collection of such an amount.
(b)For the purpose of enforcing payment under the provisions of subsection (a), an assessing officer may levy a distress, in accordance with the provisions of section 5(1) of the Tax (Collection) Ordinance, also on a vehicle of the debtor parked in a public place, provided that the following are satisfied, as the case may be:
(1)the vehicle is parked in the vicinity of the debtor's premises;
(2)if the vehicle is not parked in the vicinity of the debtor's premises – the following conditions are met:
(a)prior to the distress, the vehicle was registered as distrained at the Licensing Office and a notice thereof was served on the debtor; for the purpose of service as aforesaid, the provisions of section 12b of the Tax (Collection) Ordinance shall apply;
(b)the assessing officer made a genuine effort to notify, shortly before the distress, the debtor, and if the debtor is a corporation – the person who regularly drives the vehicle, the debtor's representative, or the registered office of the corporation, of the intention to levy distress on the vehicle;
(c)the vehicle is not registered as a vehicle of a person with a disability in accordance with the registration at the Licensing Office.
Guarantor for payment of a tax debt§
193a.
Where a guarantee has been given to the assessing officer, by way of a surety, to secure payment of a debt that a person is liable to pay under this Ordinance, as a condition for the extension of the time for payment of the debt in accordance with section 186, the assessing officer may enforce fulfilment of the surety under the Tax (Collection) Ordinance or through a court competent to do so; however, proceedings under the Tax (Collection) Ordinance shall not be taken unless all of the following have been satisfied:
(1)the assessing officer is entitled to collect the debt from the debtor under section 193;
(2)the debt is under Chapter I of Part 10;
(3)there is no bar to demanding fulfilment of the obligation from the guarantor under the provisions of the Guarantee Law, 5727-1967;
(4)the guarantor was informed, orally and in writing, on a form prescribed by the Director and signed by the guarantor, that fulfilment of the surety will be enforced in this manner.
Collection of tax in special cases§
194.
(a)Where the assessing officer had reason to fear that the tax on a particular income will not be collected because a particular person intends to leave Israel, or for any other reason, he may –
(1)if that person has already been assessed in respect of that income, or is liable to pay advance payments in respect thereof – demand by written notice that the person immediately furnish security, to the satisfaction of the assessing officer, for payment of the tax assessed or the advance payments he is liable to pay;
(2)if the person has not yet been assessed as aforesaid – assess him according to the amount of income on which the return was submitted, and if that person did not submit a return or submitted one that does not satisfy the assessing officer – according to an amount that appears reasonable to the assessing officer;
(3)if the person was not yet liable to submit a return on that income – to demand from him by written notice to immediately prepare a return, after which the assessing officer shall be entitled to act as provided in paragraph (2).
(b)Where an assessment has been made under subsection (a)(2), the assessing officer shall give notice thereof and any tax assessed under that assessment shall be paid immediately upon delivery of the notice.
(c)Where the taxpayer has not paid the tax or has not furnished the security under subsection (a)(1), a competent court may, on the application of the assessing officer, make an order, even in the absence of the taxpayer –
(1)for the stay of his departure from the country;
(2)for the attachment of his property, and if satisfied that there is reasonable apprehension that the tax will not be collected and that attachment is insufficient to secure its collection – for the seizure of his property.
(c1)Where the taxpayer is a closely-held company as its meaning in section 76, a competent court may order, under the provisions of subsection (c)(1), a stay of departure from the country of any active director, business manager or member holding shares entitling him to 25% or more of the voting power therein or to 25% or more of its capital in the event of liquidation, provided that the stay of departure from the country is required for the purpose of collecting tax in special circumstances under section 119a or for the purpose of an investigation or other action necessary to secure payment of the tax, and the court is satisfied that the departure from the country is liable to frustrate such collection, action or investigation and that it is not possible to impose appropriate security to ensure their fulfilment.
(d)A taxpayer who has paid the tax or furnished security under this section is entitled to submit an objection and appeal under sections 150–158, and the amount he paid shall be adjusted according to the outcome.
Application to the Centre Registrar for the imposition of restrictions§
194a.
(a)Where proceedings have been commenced under the Tax (Collection) Ordinance for the collection of an amount that a person is liable to pay under this Ordinance, the Director may apply to the Centre Registrar in the district in which the debtor's place of residence or place of business is located, with a request to impose on the debtor one or more restrictions under section 7a(c) of the Fines Collection Centre Law, for the purpose of collecting the debt, provided that at the time of the application all the tax debts of that debtor in respect of which proceedings for collection have been commenced under the Tax (Collection) Ordinance on account of a debt under this Ordinance, under the Land Taxation Law, under the Value Added Tax Law, under the Customs Ordinance, under the Purchase Tax (Goods and Services) Law, 5712-1952, and under the Fuel Excise Law, 5718-1958, shall be brought before the Centre Registrar, and the decision of the Registrar shall apply to all such debts.
(b)The Director's application to impose a restriction as referred to in subsection (a) and the decisions, proceedings and rules of procedure in respect of such a restriction shall be governed by sections 7a to 7f of the Fines Collection Centre Law, with the necessary modifications and the following modifications: in section 7a(a)(2) of that Law, instead of "a year" read "a month", and after "the provisions of section 5" read "and a year or more has elapsed from the date on which a warrant of authorisation was issued for the collection of that debt under section 4 of the Tax (Collection) Ordinance".
(c)Notwithstanding the provisions of section 231(a), the Director may disclose to the Centre Registrar any information required by him for the purpose of exercising his powers under this section.
(d)In this section –
"Centre Registrar" – as its meaning in section 6a of the Fines Collection Centre Law;
"Fines Collection Centre Law" – the Fines, Fees and Expenses Collection Centre Law, 5755-1995.
Claim by the assessing officer§
195.
Tax may be claimed and recovered together with all costs from the person liable to pay it by the assessing officer in his official name in a competent court, as if it were a debt to the Government of Israel, and it may be claimed and recovered by him in the manner prescribed in section 193.
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Contact Us →Section E: Appropriation of a Taxpayer's Payments
Appropriation of payments§
195a.
(a)Where a person paid any amount on account of a tax debt, a proportional part of the amount paid shall be appropriated against each type of liability in that tax debt, in the ratio that the portion of the amount of that type bears to the total tax debt; for this purpose –
(1)if the person did not specify whether the amount he paid is on account of his liability as a taxpayer or as a withholder, the amount shall be appropriated to his liability as a withholder;
(2)a tax refund set off under the Tax Set-Off Law, 5740-1980, against a tax debt, and an amount collected under the Tax (Collection) Ordinance or in any other manner, shall have the same effect as amounts paid by a person.
(b)
(1)Where a person paid an amount on account of a tax debt he owes as a taxpayer and did not specify the year of the debt, the amount shall be appropriated to his tax debts as a taxpayer in the order in which they arose, commencing from the earliest tax year;
(2)Where a person paid an amount on account of a tax debt he owes as a withholder, the amount shall be appropriated to his tax debts as a withholder in the order in which they arose, commencing from the earliest.
(c)In this section –
"tax debt" – any of the following:
(1)the total of all amounts of all types of liability that a person owes under this Ordinance as a taxpayer in respect of a particular tax year;
(2)the total of all amounts of all types of liability that a person owes under this Ordinance as a withholder in respect of a particular payment he made to another person;
"type of liability" – any of the following: tax, interest, linkage differentials.
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Contact Us →Section F: Monetary Sanction in respect of an Online Return
Monetary sanction§
195b.
(a)Notwithstanding the provisions of Section C, where the Director has reasonable grounds to assume that an online return has not been submitted by the date referred to in section 132 or 166, as the case may be (in this Section – the contravention), he may impose on the contravener a monetary sanction of NIS 600 for each full month of delay in submitting the return.
(b)Where the Director has reasonable grounds to assume that a money changer did not submit a return under section 141a, he may impose on the contravener a monetary sanction of NIS 6,000 for each full month of delay in submitting the return.
(c)Where the Director has reasonable grounds to assume that a money changer did not submit a non-execution-of-transaction report under section 141a(a), he may impose on the contravener a monetary sanction in the amount referred to in subsection (a), for each full month of delay in submitting the return.
Demand for monetary sanction and its payment§
195c.
A monetary sanction for a contravention under section 195b shall be paid pursuant to a written demand by the Director, in a form prescribed by him (in this Section – the liability notice), within 30 days from the date of dispatch of the liability notice; the liability notice shall set out, inter alia, the particulars of the contravention on account of which the monetary sanction was imposed and its rate, and shall also include information regarding the right to present arguments before the Director, as referred to in section 195d.
Statement of Claims§
195d.
(a)An individual, employer or withholder to whom a notice of liability has been sent may, within 30 days from the date of dispatch of such notice, submit to the Director, in writing, their claims with respect to the imposition of the monetary sanction and its rate (in this Section – statement of claims); the statement of claims shall be accompanied by an affidavit attesting to the facts set out therein.
(b)Where an individual, employer or withholder has submitted a statement of claims to the Director, the Director shall decide, on the basis of the statement of claims and the affidavit, whether to leave the notice of liability in force or to cancel it, and may, for the purpose of making such a decision, summon the person who submitted the statement of claims to a hearing before the Director; notice of the Director's decision under this subsection shall be sent to the person who submitted the statement of claims.
(c)The submission of a statement of claims under this Section shall not operate to stay payment of the monetary sanction at the time referred to in section 195c.
(d)Where the monetary sanction has been paid and the Director has decided under this Section to cancel the notice of liability, the monetary sanction shall be refunded together with linkage differentials and interest as defined in section 159a(a), from the date of its payment until the date of its refund.
Update of the Amount of the Monetary Sanction§
195e.
(a)A monetary sanction shall be in accordance with its updated amount on the date of dispatch of the notice of liability, and if a petition has been filed and the court hearing the petition has ordered a stay of its payment – in accordance with its updated amount on the date of the decision on the petition.
(b)The amount of the monetary sanction shall be updated on 1 January of each year (in this Section – the update date), according to the rate of increase of the index known on the update date as compared with the index that was known on the update date of the preceding year, and with respect to the first update date – as compared with the index that was known on 1 January 2008; the said amount shall be rounded to the nearest amount that is a multiple of NIS 10.
(c)The Director shall publish, by notice in the Reshumot (Official Gazette), the updated amount of the monetary sanction.
195f.§
(Repealed — תשע״ו־5)
Collection§
195g.
The collection of the monetary sanction shall be governed by the Tax (Collection) Ordinance.
Preservation of Criminal Liability§
195h.
(a)Payment of a monetary sanction shall not derogate from the criminal liability of an individual, employer or withholder in respect of the breach.
(b)Where an indictment has been filed against an individual, employer or withholder for an offence under section 216(4) or (4a), that person shall not be charged in respect thereof with payment of the monetary sanction, and if they have paid – the amount paid shall be refunded together with linkage differentials and interest as defined in section 159a(a), from the date of its payment until the date of its refund.
Petition to an Administrative Affairs Court§
195i.
(a)The filing of a petition to a court against a charge to pay a monetary sanction under this Section, in accordance with item 32(5) of the First Schedule to the Administrative Affairs Courts Law, 5760-2000, shall not operate to stay payment of the monetary sanction, except with the consent of the Director or if the court so ordered.
(b)Where a petition as referred to in subsection (a) has been granted after the monetary sanction has been paid, the monetary sanction shall be refunded together with linkage differentials and interest as defined in section 159a(a), from the date of its payment until the date of its refund.
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