Tax Disputes and Investigations

  • We act for commercial clients who are in dispute with the Israeli tax authorities, advising on all aspects of direct and indirect tax-related claims as well as tax investigations. We also advise on contractual disputes relating to tax matters, such as tax indemnity claims under a plan of merger or share purchase agreement.


    Combining S. Horowitz & Co.'s leading skills in dispute resolution and our formidable expertise in tax law, we have developed one of Israel's premier tax disputes and tax investigations practices. Our clients range from multinationals and financial institutions to emerging companies over a broad range of industries as well as high net worth individuals.


    The team's expertise includes:


    • Representing clients before the Israeli tax authorities in respect of disputed tax assessments
    • Settling disputed tax assessments on terms which aim to be the most favourable to the client
    • Dealing with any threatened or commenced tax investigations
    • Representing clients in criminal and civil court proceedings relating to any tax disputes
    • Advising on tax related contractual disputes
    • 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
    • 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 building materials supplier and cement producer, 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