An article authored by firm partners Adv. (CPA) Meori Ampeli and Adv. Anna Tsabari has been published in Tax Notes International (Volume 122, April 20, 2026), one of the world's leading international tax journals.
The article examines:
The Multinational Group Minimum Corporate Tax Law (5786-2025), effective January 1, 2026, implementing the OECD Pillar Two / GloBE rules into Israeli domestic law
The QDMTT mechanism and the computation of the top-up tax to bring the effective tax rate up to the 15% minimum threshold
The two available reporting tracks — individual and group-consolidated — and the criteria for selecting between them
The implications for companies benefiting from preferential rates under the Law for the Encouragement of Capital Investments (5–12% tax rates), and the qualified refundable tax credit (QRTC) mechanism introduced as an alternative incentive framework
Practical action items for MNE groups in Israel, including ETR mapping, application of transitional provisions, and compliance with notification deadlines
The article is available on the Tax Notes website, subscription required: read the Tax Notes International article.