Israel Presumed Management and Control Test for Tax Residence Purposes

According to recent reports, the Israeli government has finalized draft legislation for the introduction of a presumed management and control test for tax residence purposes for certain offshore companies in low tax jurisdictions. Under current rules, a company is generally deemed to be resident in Israel if it is incorporated under Israeli law or is managed and controlled from Israel. Under the draft legislation, an offshore company would be presumed to be managed and controlled from Israel,…