Corporate Taxation

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  • We advise our clients on all tax aspects of corporate life, from commercial agreements through to corporate transactions, including cross-border and domestic mergers and acquisitions, joint ventures, corporate structuring, reorganisations, restructurings and related workout transactions, private equity investments, angel investments, public offerings and private placements. Working together with our corporate department, our corporate tax team has a long track record assisting its clients in the tax structuring of mergers and acquisitions and obtaining Israeli tax rulings that are necessary for closing to take place.

     

    We guide our clients through the Israeli tax implications of their transactions and corporate operations, devising tailor-made tax efficient solutions while mitigating or minimising their exposure to tax. As part of our services, we advise our international clients on the corporate tax aspects of the establishment, operation and winding up of their local subsidiaries or joint ventures, whether they are in corporate form, by way of partnership or involve other contractual arrangements. As a high volume of our work involves international and double taxation considerations, we work together with leading foreign tax advisers in order to provide clients with a seamless service.

    • Representing one of Israel's largest food retail chain companies, on an income tax dispute regarding the tax years 2008-2011, concerning the deduction of major expenses in the amount of over 100 million shekels (approximately US$ 25 million) arising from a substantial series of inter-related transactions.  Our assistance included negotiations with senior tax representatives and ultimately the execution of an extremely favourable agreement for the client with the tax authorities
    • Representing Dubek Ltd., Israel's largest cigarette manufacturing company, in a dispute with the tax authorities concerning purchase tax and VAT payable in connection with the export of cigarettes for subsequent sale abroad.  Our assistance included representing Dubek in legal proceedings before the court, including appeals, the managing of complex and numerous negotiations with the tax authorities and ultimately the execution of settlement agreements with both the tax authorities and the Attorney General
    • Advising Veolia Environnement S.A. on the tax issues arising from the NIS 1.2 billion (approximately US$ 340 million) sale of its entire operations in Israel to Oaktree Capital Group (a private equity fund) and the current management of Veolia's Israeli operations, the largest management buy-out in Israel's history. Our services included advising on international tax, corporate tax, withholding tax and other tax issues
    • Representing Dubek Ltd. on the tax aspects of its reorganisation and the transfer of its real estate assets to an affiliate.  Our services included tax planning regarding reorganisation, representing the client before the tax authorities, applying for and obtaining the necessary tax rulings to effect the reorganisation
    • Representing the Israel Infrastructure Fund and its partners, providing them with tax advice and accompanying them through tax ruling proceedings regarding the Fund’s US$ 110 million preferred equity investment in Israel's largest privately-owned gas-powered electricity station in Tel Tzafit, constructed by Dalia Power Energies Ltd.
    • Representing Radiancy in its US$ 150 million reverse acquisition of PhotoMedex, a US company dually listed on NASDAQ and the TASE, including by way of provision of tax advice on structuring the transaction, the provision of tax opinions, and representing Radiancy before the tax authorities in reaching favourable tax agreements and rulings
    • Representing AT&T on all the Israeli tax aspects of its acquisition, by way of reverse triangular merger, of Interwise Inc., a major player in the internet web-conferencing space, for a consideration of US$ 121 million
    • Representing the Israel Electric Company on various issues, including a major tax dispute valued at approximately NIS 5 billion (US$ 1.25 billion) concerning taxation of its natural gas projects, the issue of debentures, employee benefits, and disputes with Israel’s National Insurance Institute
    • Representing Shapir Civil and Marine Engineering Ltd., Israel’s largest construction, development and civil engineering company, providing tax advice and negotiating various agreements with the Minister of Finance and the tax authorities for the receipt of a licence to set up a fuel company and become a fuel licensed taxpayer
    • Representing Readymix Israel and Cemex Israel, a subsidiary of CEMEX, the world's largest concrete manufacturer, in connection with restructuring of the group, its tax structure, M&A tax planning, and in disputes with the property tax authorities concerning many of its assets in Israel
    • Representing Lime and Stone Ltd., Israel's largest producer of aggregates, in connection with various tax issues, and in reaching a tax settlement with the VAT authorities

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