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Israeli Double Tax Treaties: Circular 4/2016

Circular 4/2016 was published by the ITA on April 2016. It aims to explain under what conditions the ITA may claim to attribute foreign corporation revenues from the sale of goods or provision of services via the internet, to a "permanent establishment" in Israel. For this reason, the Circular describes different cases where a permanent establishment may exist in Israel:

  1. A branch, an office or another facility used for the activities of the foreign corporation in Israel;

  2. Representatives in Israel, engaged in certain activities for the foreign corporation, such as recruiting clients, collecting information, communicating with the clients on an ongoing basis (for example, organizing conferences for customers, creating opportunities to display new products, developing and improving the service provided to the customer), marketing, collecting, technical support, consulting;

  3. A "significant economical presence" in Israel (for example, signing a significant number of contracts for the provision of digital services with Israeli residents, a vast amount of customers in Israel are consuming online services offered by the foreign corporation provision of online services tailored to customers in Israel); activities of multinational corporations operating in Israel through the internet with the assistance of Israeli corporations or subcontractors related to other Israelis.


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