In accordance with section 75H1 of the Ordinance. The IRBT is a trust in which all Settlors, from the date of creation, are foreign residents, and during the tax year there is at least one Israeli resident Beneficiary.

IRBT trust which does not satisfy the conditions specified for the Relative Trust is considered as Israeli Residents Trust, and therefore the income and the assets of the Trustee will be viewed as the income and assets of an Israeli resident and will be taxed in Israel.