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Israel Adopts Virtual PE Concept Based on a Significant Digital Presence

19 April 2016

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Approved Changes

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Israel

On 11 April 2016, the Israeli Tax Authority (ITA) issued Circular No. 4/2016, which sets out the ITA's position on the attribution of income to a permanent establishment in Israel derived from the supply of digital services (Virtual PE).The circular is the official version of the draft circular issued in April 2015. While related to the work done on Action 1 (Addressing the Tax Challenges of the Digital Economy) of the OECD BEPS Project, the ITA has decided to adopt the concept of a significant economic presence to determine if a PE exists, which is a concept that was not...