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Israel Draft Regulation for Modified Nexus Approach

05 May 2017

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Proposed Changes

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Israel

According to recent reports, Israel's Ministry of Finance has approved draft regulations to ensure the country's IP regime is in line with the modified nexus approach developed as part of BEPS Action 5 ({News-2017-02-03/A/4- previous coverage}). The main aspect of the regulation is the application of the nexus formula to determine the amount of IP-related income that qualifies for the reduced tax rates provided by the IP regime: (Qualifying R&D Expenditure x 130% (uplift) / Total R&D Expenditure) x Taxable Income from IP. The 30% uplift provides for the inclusion of a portion of the non-qualifying expenditure. Qualifying expenditure includes...