Ms. Shavit is the head of FBC's Tax Department and is recognized by international and domestic indices as one of Israel's leading tax practitioners.
Her diverse practice encompasses income tax, VAT, real estate tax, international tax matters, taxation of provident funds, tax implications of employee benefit plans, and compensation packages. Ms. Shavit also has considerable experience working with governmental and regulatory agencies involved in privatizations and restructurings.
Ms. Shavit has broad experience in handling complex M&A, financing, and capital markets transactions, and in the representation of venture capital and private equity funds in fund formation matters, as well as regarding investments in portfolio companies.
Ms. Shavit’s on-going work for Israeli and multinational clients includes advising on cross-border tax structuring, representation before the Israeli tax authorities in ruling requests and settlement agreements, and providing opinions on tax-related issues.
Ms. Shavit is Co-Chair of the Tax Committee of the Central District of the Israel Bar Association.
Tel Aviv University, LL.B., 1994
Tel Aviv University, B.A. (Economics), 1994
An inter-ministerial committee was recently set up to promote the establishment of publicly traded funds for investment in infrastructure. The committee was formed to examine and recommend measures and actions that would encourage the establishment of traded infrastructure funds in order to increase the availability of financing sources for infrastructure projects, reduce the financial costs of these projects and enable small investors to directly participate and own these projects.
Transfer pricing rules deal with pricing and profit attribution rules of international transactions performed between two or more related parties (eg, a parent and its subsidiary). This article provides a high-level overview of some of the common business models used by local entities that are engaged in the distribution, sale and marketing of their group's products and analyses the potential transfer pricing ramifications thereof.
Among the primary tools for encouraging inbound investments in Israel is the special tax regime for private investment funds. Over the years, the Tax Authority has issued substantial guidance and numerous private rulings under the Income Tax Ordinance, providing significant tax benefits to foreign investors and private investment funds operating in Israel. This article outlines the income tax arrangements applicable to private investment funds operating in Israel.
Recent years have seen a significant increase in publicly raised capital on the stock market by partnerships engaged in oil and gas exploration, which presents challenges due to existing tax legislation in Israel. In general, the process established in the law creates a distortion under which present partners will pay additional tax for past partners who benefited from the partnership's profits in a particular year.
The Tax Authority recently published a tax ruling addressing priority technological enterprise status with respect to an Israeli company that engages in the development and provision of cloud service platforms. The ruling provides that, subject to the Investment Law, income derived from the right to use a company's cloud platforms will be classified as income generated by a technological enterprise and, therefore, will be entitled to the Investment Law's reduced tax rates.
The Israel Tax Authority (ITA) recently published a tax circular to clarify cases in which a transfer pricing study filed by a taxpayer will be considered to fulfil legal requirements and thus shift the burden of proof in the assessment process framework to an ITA inspector, in contrast to the general rule that the burden of proof rests with the taxpayer.
The Value Added Tax (VAT) Law sets out that zero-rate VAT applies to the export of services to a foreign resident. However, recent judgments have interpreted such relief in a narrow manner and have significantly reduced the ability to charge zero-rate VAT on services rendered to foreign residents.
In a recent decision, a district court in Israel ruled in favour of Broadcom Semiconductor Ltd and rejected the Israeli Tax Authority's claim that Broadcom Semiconductor was required to pay additional taxes of NIS100 million due to the deemed sale of its main functions and assets to affiliated companies. In its decision, the court ruled that a change of a company's business model would not necessarily be deemed as a sale of its assets (and, in particular, a sale of its intellectual property).
The Organisation for Economic Cooperation and Development (OECD) set a goal to deliver by 2020 a final report that includes a consensus approach with respect to the challenges of the digital economy, both the allocation of taxation rights (pillar one) and Base Erosion and Profit Shifting issues (pillar two). What are the latest proposals of the OECD and where does Israel stand?
The taxation of real estate investments is complex and depends on various factors, including the property owner's status (ie, individual or corporation), the nature of the asset (eg, residential property, commercial property or land) and the purpose of the investment (eg, producing rental income or entrepreneurial profit). This article summarises the main factors to be considered when contemplating real estate-related investments in Israel.