Full local support for international companies entering Israel

Choosing the right structure

The structural decision comes first. We analyze the options — Israeli subsidiary, branch, or EOR — considering planned scale, home country, treaty network, IP roadmap and future funding.

End-to-end setup process

Once the decision is made we handle everything:

• Company registration with the Registrar (2–3 business days)
• Registration with VAT, ITA and Bituach Leumi
• Bank account opening with full KYC representation
• Employer registration and payroll setup
• Accounting system tailoring for the entity's needs

Global Payroll & Israeli labor law

Employing in Israel means compliance with a dense set of local labor obligations — every one of which we manage as your local finance function:

• Monthly payslips compliant with Israeli labor law
• Pension, severance and study fund contributions
• Reporting to Bituach Leumi and income tax withholding
• Executive compensation, options (Section 102 – Equity & ESOP Incentive Plans) and equity awards
• Termination, severance settlements and Form 161 filings
• Global payroll coordination with parent HR systems

Ongoing management & parent reporting

After setup we operate as your local finance team — day-to-day bookkeeping, VAT and tax filings, monthly payroll, quarterly reporting packs to the parent, and annual audited financial statements aligned to the group's US GAAP or IFRS reporting standard.

Transfer Pricing & BEPS compliance

For companies with material intra-group transactions we prepare Transfer Pricing studies compliant with OECD guidelines and Section 85A of the Israeli Income Tax Ordinance. Robust documentation protects against ITA assessments and gives certainty to the group:

• Full benchmark study of comparable market transactions
• Selection of the optimal method (CUP, Cost Plus, TNMM)
• Functional analysis — functions, assets and risks
• Local File and Master File under BEPS Action 13
• Country-by-Country Reporting (CbCR) coordination
• Annual updates and defense before the ITA

Cross-Border IP Tax Structuring

The location of a group's intellectual property is one of the most consequential tax decisions — it drives effective tax rate, royalty flows and eventual Exit valuation. We plan and execute optimal IP structures in Israel and abroad, in full compliance with OECD BEPS and the Israeli Income Tax Ordinance:

• IP location strategy: Israel (Preferred Tech 6–12%), Ireland, Luxembourg, Singapore
• Intra-group technology transfers under Section 85A at arm's length
• BEPS compliance: Substance, DEMPE, Master File / Local File / CbCR
• Cost-Sharing Agreements (CSA) between Israeli parent and foreign subsidiaries
• Patent and trademark strategy, royalty models and License Agreements
• Pre-Rulings from the ITA on IP transactions and full documentation
• Optimization of withholding tax on royalties under tax treaties

Israeli tax incentives for multinationals

Foreign-owned Israeli subsidiaries can access the full range of Israeli tax incentives, dramatically reducing the group's effective tax rate — provided the Transfer Pricing story is coherent:

• Preferred Technological Enterprise — 6% corporate tax (12% standard track)
• Dividend exemption from a Preferred Enterprise in defined cases
• Immediate expensing of R&D in the year incurred
• IIA grants — 20–50% of approved R&D expenditure
• Tax treaties with 60+ countries — bilateral relief from double taxation

Fractional CFO for foreign companies in Israel

Multinationals operating in Israel need a senior local finance presence that speaks the HQ's language (US GAAP / IFRS, SOX-ready internal controls) while knowing Israeli regulation in depth. We serve as the company's Israeli Fractional CFO — the bridge between Corporate and Local — while also leading the annual statutory audit and M&A due diligence and running local payroll and Section 102 equity plans.

• Local Country Controller / Country CFO for HQ in Israel
• Monthly and quarterly reporting to HQ in the required format and currency
• Local budget control aligned with the Group plan
• Israeli banking, insurance and regulatory relationship management
• Support for statutory audits and Group internal audit
• Readiness for M&A, Carve-Out or Wind-Down