Tax & Wealth Law

In an economic world where domestic and international taxation meet, the firm helps its clients optimise the tax management of their businesses and assets (structuring of trusts and holding companies).

Given its cross-border dimension, Abitbol & Associés designs tax optimisation structures tailored to each business and each private estate.

Our tax practice has a thorough command of the France–Israel tax treaty for the avoidance of double taxation. Combined with our knowledge of local tax law, this enables us to support businesses and individuals planning to settle in Israel. We also inform them of the exemptions and incentives available to them.

Moving to Israel: the questions to anticipate

Moving from France to Israel has tax consequences in both countries. They should be reviewed before the move, not after:

• determining tax residence under each country’s domestic law and the France–Israel tax treaty;
• the French “exit tax”, which may apply, under certain conditions, to unrealised gains on shares held at the time of departure;
• the Israeli tax regime for new immigrants and returning residents, whose conditions must be checked at the time of the move;
• taxation of income that remains French-source (rent, pensions, dividends);
• reporting obligations in each country.

Businesses and investors:

• choice of structure (subsidiary, branch, holding company) for activities in Israel or France;
• payments between companies in the two countries (dividends, interest, royalties) and withholding taxes;
• assistance during tax audits and objections.

Areas of practice:

• Corporate taxation
• Personal taxation
• Taxation of real estate transactions in France and in Israel
• Tax aspects of moving to Israel
• Trusts and holding companies
• Tax litigation
• Settlements with the tax authorities