Effective as of 1 January 2025, closely held companies may be subject to ITO Section 81 provisions (addressing undistributed accumulated profits), and ITO Section 62A provisions (addressing the taxation of current earnings of these profits).The legislation in question is considered complex in its practical application, and uncertainties and gaps remain regarding how the provisions of the law should be implemented. Due to two changes made under the Economic Efficiency Act that the Knesset approved in early January 2025, companies that fall within the definition of "closely held company" (CHC) may be subject to tax on undistributed accumulated profits and on current...