An Israeli Resident for tax purposes is defined in Section 1 of the Ordinance as an individual whose center of life is in Israel (the "Center of Life Test"). The Center of Life Test is composed of three subtests - the objective, the quantitative and the subjective tests.

1. The Objective Test considers and includes examination of the person's family, economic and social links, including, following considerations:

2. The location of an individual's permanent home;

3. The actual residency location of an individual and his family (in particular, spouse and minor children);

4. The location of business or permanent place of employment;

5. The location of assets and investments owned by an individual;

6. The location of membership in organizations, associations, and institutions of an individual. (the "Objective Test")

The Quantitative Test according to the section 1 of the Ordinance states that the center of life of an individual will be deemed in Israel, in either of the following situations:

1. An individual stays in Israel at least 183 days on a calendar tax year, ending on 31 December; and/or:

2. An individual stays in Israel at least 30 days in the current tax year and at least a cumulative total of 425 days in the current and the two preceding tax years. (the "Quantitative Test")

The subjective test examines the individual's intention, i.e. where he considers the center of his life and whether his intentions are expressed and supported by his actions in a real time