Treaty between Israel and Belgium – Israeli Court decision on "management and control" of a company

On 18 December 2013, the Tel Aviv District Court's decision in the case of Yanko Weis Holdings Ltd v. the Holon Income Tax Assessor (C-1090/06) became publicly available. The decision concerns the tax residency of a company based on the place of its management and control. Details of the case are summarized below.
(a) Facts. A company incorporated in accordance with the laws of Israel was registered in Belgium, and its formally registered directors were also registered in Belgium. The company so…