Non-resident investors not doing business in Israel are generally exempt from Israeli capital gains tax (CGT) when they sell Israeli securities acquired on or after 1 January 2009. However, exceptions were introduced with Amendment 197 to the Income Tax Ordinance, which are clarified by the recently issued Circular No. 3/2014. According to Amendment 197 and the circular, the CGT exemption for non-residents does not apply for Israeli securities that directly or indirectly derive their main value on their date of purchase and in the two years before their sale from: Israeli real estate rights or rights to a real estate...