PART TEN: PAYMENTS AND COLLECTION 
CHAPTER ONE: DEDUCTIONS ON ACCOUNT OF TAX 
Article One: Deductions from Dividend and Interest 
161. Repealed 
Set off of tax on dividend and interest 
162. If a body of persons deducted tax from interest or dividends, and if that
interest or dividend or part of it is included in the recipient's income, then 
the 
tax deducted shall be set off against the tax imposed on that income. 
Relief from tax on the dividends of foreign companies from Israel income 
163. (a) If an ordinary dividend was paid to a person who under this Ordinance
is liable to tax on it, and if he proves to the Assessing Officer's 
satisfaction that the dividend was paid by a company that is not resident 
in Israel and that the company's income, out of which the dividend was 
paid (hereafter: the relevant income) includes income on which the 
company paid tax under this Ordinance, whether by deduction or in 
some other manner (hereafter: Israel income), then he shall be entitled 
to tax relief on a proportional part of the dividend, in the proportion of 
the Israel income to all the relevant income (hereafter: Israel dividend). 
(b) The rate of relief shall be equal to the rate of tax paid by the company 
under this Ordinance or to the rate of tax applicable to the Israel 
dividend, treated as the highest part of that person's income, whichever 
is the lower rate. 
(c) If relief was granted to a person under this section in respect of an 
Israel dividend, then both the amount of that relief and the amount of 
the dividend shall be deemed his income from that dividend. 
(d) Any relief granted under this section shall, for the purposes of section 
201, be deemed to reduce the amount of tax chargeable under this 
Ordinance in respect of the said dividend. 
(e) For purposes of this section: 
"ordinary dividend" – a dividend on a share which is not a preferred 
share and also that amount of dividend on a preferred share which is 
not paid at a gross percentage rate; 
"preferred share" – a share which carries the right to dividends at a 
fixed gross percentage rate, payable before any dividends on other 219 
classes of shares, whether or not it also carries the right to some further 
participation in profits; 
"tax" – not including companies tax. 
Article Two: Deduction from Work Income and from Other Income 
Obligation to deduct at source 
164. Any person who pays or is responsible for the payment of work income, 
including the part of a grant received in consequence of retirement or death 
that is not exempt under section 9(7a), of earnings or profit that stem from 
gambling, lotteries or prize winning activity, as said in section 2A, of the 
amount received from capitalization of a pension which is not exempt under 
sections 9A or 9B, of amounts and payments to which section 18(b) applies 
and which constitute income for their recipient, of income under section 2(5),
of chargeable income that a real estate investment fund, as defined in section
64A2, transmits to its members, of consideration within its meaning in section
88, of interest or dividends, or of any other income which the Minister of 
Finance with approval by the Knesset Finance Committee so designated by 
Order, shall – when payment is made – deduct tax from the amount to be 
paid in the manner and at the rates prescribed, but the Minister of Finance 
may prescribe that – in respect of gains or profit said in section 2A – the tax
deduction shall be as he shall prescribe, even if not at the time payment is 
made and not out of the amount to be paid; this provision also applies to the
State. 
Set off of deduction 
165. (a) The said deduction shall be set off against the tax due from the 
recipient's chargeable income in the tax year in which the deduction 
was made or in the following tax year, at the Assessing Officer's option 
at the time of or before the assessment. 
(b) A set off under subsection (a) against the tax to which a controlling 
member, as defined in section 32(9), is liable shall only be made after 
the deducted amount has been paid to the Assessing Officer, unless 
the member's control is less than 50% and he proves to the Assessing 
Officer's satisfaction that he did not know that the deducted amount had 
not been paid to the Assessing Officer or that he took all reasonable 
measures to ensure its payment. 
Obligation of person who makes the deduction 
166. (a) When a person has deducted tax under section 164, then he shall pay 
the amount of tax deducted to the Assessing Officer at the time 
prescribed by regulations, and at the same time he shall deliver to him 
a return as prescribed. 
(b) An employer or a person who deducted shall submit a return said in 
subsection (a) in respect of the payment of an employee's work income 
(Form 0126) and in respect of income liable to deduction (Form 0856) 
in the online manner, as the Director shall prescribe, until April 30 after 
the tax year in respect of which it is submitted, together with a 
declaration on a Form prescribed by the Director, according to which 
the particulars and the information given in the return are correct and 
complete, as well as a printout of the said return signed by him 
(hereafter: employer's online return and deductor's online return, as the 
case may be). 220 
(c) In this section – 
"income liable to deduction" – payments designated under section 
164 as income for purposes of the said section, as specified below: 
(1) insurance commission; 
(2) artists', examiners' and lecturers' fees, 
(3) writers' fees; 
(4) payments for agricultural work or produce; 
(5) payments for construction work and haulage; 
(6) payments for garment making, metal work, electrical and 
electronic work and haulage; 
(7) payments for diamond work; 
(8) payments for services or assets; 
"employee" – other than an employee who works in an individual's 
private household. 
Assessing Officer may assess deductions 
167. (a) If a person, to whom the provisions of sections 161 or 164 apply, did
not deduct tax as provided by them or did not deliver a return as said in 
sections 161 or 166, or if he delivered a said return, but the Assessing 
Officer has reasonable grounds for believing that the return is not 
correct, then the Assessing Officer may, to the best of his judgment, 
assess the amount that person should have deducted, and this 
assessment shall not relieve that person from any other responsibility 
under this Ordinance; an assessment under this subsection shall be 
treated like an assessment under section 145; the Assessing Officer 
may assess a person as said in this section during the period said in 
paragraph (1) or in paragraph (2), whichever is later: 
(1) during the period in which he may – to the best of his judgment – 
determine that person's chargeable income for the tax year in 
which is obligated to deduct tax; 
(2) within three years after the end of the tax year in which the liable 
person's last deductions return for the tax year was submitted 
under the provisions of sections 161, 164 or 234, and with the 
Director's approval – within four years after the end of the said tax 
year. 
(b) The provisions of subsection (a) shall also apply when an assessment 
or an Order which is no longer open to contestation or appeal has been 
made for the year to which the return relates in respect of the person 
from whose income the tax should have been deducted, if that 
assessment or Order does not include the income from which the 
deduction should have been made. 
Right of objection 
168. If a person disputes the correctness of an assessment under section 167, he
may, within two weeks, deliver a written objection to the Assessing Officer, 
and the provisions of sections 150 to 158 shall apply as if the objection had
been filed under those sections; the amount of tax, determined by the 
assessment by Order under section 152(b) or in an appeal under section 153, 
shall be paid within seven days after notice of assessment was delivered or 
after the Order was made or the judgment handed down, all as the case may 
be, or by another date prescribed by regulations. 
169. Repealed 
221 
Article Three: Deduction from Foreign Resident 
Obligation of person who pays to a foreign resident 
170. (a) A person who pays to a person who is not resident in Israel – or to 
another for him – any income that is chargeable under this Ordinance – 
other than income from which tax was deducted under sections 161 or 
164 – shall deduct from that income tax at the rate of 25 agorot for 
every shekel at the time of its payment, if the recipient of the payment is 
an individual, or tax at the rate imposed by sections 126 and 127 if the 
recipient is a body of persons, or at another rate the Assessing Officer 
will prescribe for them by written notice; however, the Assessing Officer 
may permit the income to be paid without deduction of tax, if it has been 
proven to his satisfaction that the tax already was paid or that it will be 
paid in some other manner; for this purpose: "person who pays" 
includes a financial institution, as defined in the Value Added Tax Law 
5736-1975, through which the income is paid, unless the financial 
institution holds certification from the Assessing Officer, exempting it 
from the obligation to deduct at the source. 
(b) The provisions of subsection (a) shall not apply to a person who pays 
income said in subsection (a) and who, under sections 108 to 115, is 
himself responsible for paying tax on it. 
(c) Notwithstanding the provisions of subsection (a), if a real estate 
investment fund, as defined in section 64A2, transmits chargeable 
income of shareholders, within its meaning in section 64A4, to a person 
not resident in Israel, then it shall deduct from it tax at the tax rate that
obligates it under the said section. 
Obligation of the person who deducts from a foreign resident 
171. When a person has deducted tax under section 170(a), then he must pay the
amount of tax he deducted to the Assessing Officer within seven days after 
the day of deduction, and he shall deliver a return to him, specifying the name
and address of the person to whom or for whom the income was paid. 
Set off of deduction 
172. The amount of deduction under section 170 shall, for purposes of 
collection, 
be set off against the tax that will be imposed on the person who received the
said income. 
Assessing Officer may assess deduction 
173. If a person is under obligation to deduct tax under the provisions of this 
Article 
and does not deduct all or part of the amount, or if he did not deliver a return
said in section 171, or if he delivered a said return but the Assessing Officer
has reasonable grounds for believing that the return is not correct, then the
Assessing Officer may assess the amount of tax which that person was 
obligated to deduct to the best of his judgment; an assessment under this 
section shall be treated like an assessment under section 145; the Assessing 
Officer may assess a person said in this section during the period during 
which he may determine – to the best of his judgment – that person's 
chargeable income in the tax year in which he was under obligation to deduct 
the tax; that assessment shall not relieve that person from any other 
responsibility under this Ordinance. 
222 
Article Four: Auxiliary Powers 
Power to enter, inspect and interrogate 
173A.(a) If the Assessing Officer deemed it necessary to do so in order to 
ensure compliance with the provisions of this Chapter or with any 
provisions on tax deduction at the source or in order to prevent evasion 
from compliance with them, then he or a public servant so authorized 
by him in writing may – 
(1) enter the premises – except a dwelling not used for his business 
or vocation – of any person who must deduct tax at the source, or 
who has possession of the books and documents that relate to 
tax deduction at the source, and he may inspect any register, 
record, certificate or other document related to tax deduction at 
the source, which is in their possession; 
(2) interrogate any person who is required to deduct tax at the 
source or who has possession of the books and documents that 
relate to tax deduction at the source or from whose income the 
tax must be deducted; 
for the purposes of paragraphs (1) and (2), "tax deduction at the 
source" – deduction of tax under sections 161, 164 or 170. 
(b) If a person is interrogated or if his premises are inspected under 
subsection (a), then he shall give the person who interrogates him or 
who makes the inspection every opportunity to do so, and he shall 
answer all questions put to him completely and truthfully. 
(c) The provisions of this section shall not derogate from any powers of an 
Assessing Officer or public servant under this Ordinance. 
Article Five: Miscellaneous Provisions 
Postponement because of holidays 
173B. The last date for the submission of a return under this Chapter shall be
postponed, if there were at least three days of rest during the five days that
preceded the said date, and it shall be on the fourth working day after the end
of the consecutive days of rest; for this purpose: "days of rest" – the days of
rest prescribed in the State of Israel within their meaning in section 18A(a) of
the Law and Administration Ordinance 5708-1948, as well as interim festival 
days. 
CHAPTER TWO: COLLECTION 
Article One: Advance Payments 
Definition 
174. In this Article, "the determining year" – the last tax year in respect of 
which 
the income of the assessee was assessed by January 1 of the tax year, 
whether or not objection was lodged. 
Assumption 
174A Spouses shall be deemed, for purposes of this Article, a single assessee; 
this 223 
provision shall not derogate from the provisions of section 66A. 
Advance payments 
175. (a) On the fifteenth day of each of the ten months from February to 
November of each tax year every assessee shall, on account of the tax 
for that tax year, make an advance payment of 10% of the amount of 
tax to which he became liable for the determining year; however, if that 
taxpayer was allowed to calculate his income according to a special 
period, as said in section 7, then he shall pay the said advance on 
account of tax for the tax year in which ends the special period that 
includes the date for the said advance payment. 
(b) Notwithstanding the provisions of subsection (a), the Minister of 
Finance may prescribe, with approval by the Knesset Finance 
Committee, in general or for categories of assessees, monthly advance 
payments that shall be a portion of those assessees' turnover of 
transactions during the period during which the advances are paid; the 
rate of advance payment shall be set according to the ratio between the 
assessee's turnover of transactions in the determining tax year and the 
tax he was obligated to pay in that year on that turnover; for this 
purpose: "turnover of transactions" – the total of transactions, as 
defined in the Value Added Tax Law 5736-1975, excluding sales to 
which Part Five or the Land Appreciation Tax Law 5723-1963 apply; the 
Minister of Finance may – in Rules – add or detract categories of 
transactions, of income or of sales, either in general or for categories of 
assessees, all on conditions which he shall prescribe. 
(c) If, during the determining tax year, a body of persons paid amounts 
said in section 18(b), other than a regular monthly salary and 
repayment of expenses (hereafter in this section: payments to a 
controlling member) to an individual who is a controlling member within 
its meaning in section 32(9), then its advances shall be in the amount it 
would have paid in that year, had it not made payments to the 
controlling member. 
(d) The amount of advance payments by a body of persons shall be 
reduced by the amounts of tax it withheld under section 164 from 
payments to controlling members. 
(e) If a transparent company received a dividend, then the amount of the 
first advance to be paid – after it was received – by it or by the share 
holders, within their meaning in section 64A1, shall be increased by an 
amount equal to 25% of the dividend. 
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As long as the provisions of section 64A remain in effect, subsection (e) 
should be read as it was before Amendment No. No. 132, as follows – Tr. 
(e) If a family company received a dividend, then the amount of the first 
advance to be paid – after it was received – by it or by the assessee, 
within its meaning in section 64A, shall be increased by an amount 
equal to 25% of the dividend. 
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(f) The last date for payment under this section shall be postponed, if 
there were at least three days of rest during the five days that preceded 
the said date, and it shall be on the fourth working day after the end of 
the consecutive days of rest; for this purpose: "days of rest" – the days 
of rest prescribed in the State of Israel within their meaning in section 
18A(a) of the Law and Administration Ordinance 5708-1948, as well as 
interim festival days. 224 
176. Repealed 
Crediting payments against advances 
177. (a) An amount deducted during the tax year at the source – under sections
161 and 164 to 170 – from the assessee's income in that tax year shall 
be deemed a payment on account of advance payments to which that 
assessee is liable under section 175 in respect of the income from 
which the tax was deducted, and he is entitled to set off any sum 
deducted at the source during the tax year in respect of which the 
advance payments are to be paid against his advance payments, on 
condition that he has written certification of that deduction. 
(b) An amount paid as an advance under section 181B in respect of an 
excess expenditure incurred in that tax year shall be deemed a 
payment on account of the advances which that assessee must pay 
under section 175, and he is entitled to set it off against his advances, 
on condition that he holds written certification of the payment of the 
advance in respect of excess expenditures. 
(c) The provisions of subsection (b) shall not apply to an amount paid as 
an advance in respect of excess expenditures by a body of persons, to 
which the provisions of section 3(g) apply. 
Doubt as to tax for the determining year 
178. If the amount of tax for the determining year is in dispute, but is greater 
than 
the amount of tax last finally determined, then the monthly advance payment 
shall be calculated according to that part of the amount of tax for the 
determining year which is not in dispute, or according to the amount of tax 
determined as aforesaid, whichever is the larger amount; "finally 
determined", in this section – by a determination not open to objection or 
appeal. 
Minister of Finance may change rates and times 
179. The Minister of Finance may, by Order, increase or reduce the rate of 
advance payments under this Article, change their payment dates or 
prescribe that they be paid once every two months or at other intervals set by
him; he may also prescribe different rates of advance payments in respect of 
different determining years and – with approval by the Knesset Finance 
Committee – for each of the advance payments during the tax year, or for 
different categories of assessees. 
Assessing Officer may exempt or increase 
180. (a) An Assessing Officer may exempt a person from all or part of an 
advance payment under this Article, if it was proven to his satisfaction 
that the tax for the year in which the advance payment is payable and in 
respect of which that assessee is likely to be liable to tax will be less 
than the tax to which he is liable in respect of the determining year, but 
he shall not so exempt a person who is required to keep account books 
and does not do so. 
(b) (1) If the amount of tax which the assessee must pay according to a 
return submitted by him under section 131 during the tax year – 
and for this purpose the Minister of Finance may prescribe a 
percentage by which the said amount of tax shall be increased – 
exceeds the amount of advance payments to which he is liable in 
respect of that year, then the Assessing Officer may increase the 225 
amount of advance payments under this Article by the amount of 
the said differential. 
(2) If the Assessing Officer has reasonable grounds for believing that 
the tax which will be due from an assessee for a particular tax 
year will exceed the amount of the advance payments to which 
he is liable for that year by at least 20% or by at least NS 
500,000, whichever is the lesser amount, then he may increase 
the amount of advance payments under this Article by the 
differential; an aforesaid decision shall, for purposes of objection 
and appeal, be treated like an assessment under section 145. 
(c) If an individual kept account books in the tax year and in the year that 
preceded it, but did not and was not required to keep account books in 
the year which serves as basis for the determination of advance 
payments in the tax year, and if the tax to which he is liable for the 
preceding tax year – according to the return submitted by him and 
based on account books – is less than the amount of advance 
payments, then the amount of advance payments to which he is liable 
in respect of the tax year shall be reduced to the amount of tax to which 
he is liable according to the return. 
Person not previously assessed 
181. If an assessee has chargeable income and previously he was not liable to 
tax 
or was not assessed, then he shall make the advance payments under 
section 175 or 176, as the case may be, in percentages of the projected 
amount of tax which he is likely to have to pay on that income in that tax year
according to his estimate, and with the first payment he shall submit to the 
Assessing Officer a declaration of the said estimated tax, and an additional 
declaration six months after the first declaration was submitted; if he did not
deliver the said declarations, or if he delivered such declarations, but the 
Assessing Officer has reasonable grounds for believing that the declarations 
are not correct, then the Assessing Officer may – to the best of his judgment
– set the amount of the advance payment which that assessee must pay, and 
a said determination shall, for purposes of objection or appeal, be treated like
an assessment under section 145. 
Power to grant reduction 
181A. The Minister of Finance may, with approval by the Knesset Finance 
Committee, prescribe by regulations reductions to be granted to persons who 
make advance payments under this Article before the time prescribed for their
payment or who make advance payments in amounts greater than what is 
due from them, all at rates and on conditions prescribed by him either 
generally or for particular categories of assessees. 
Article One "A": Advance Payment for Nondeductible Expenses 
Advance payment for excess expenses 
181B. (a) If, for purposes specified in regulations under section 31, a body of
persons spent amounts which according to the said regulations are not 
deductible or which exceed the amounts set as deductible, or if it spent 
amounts for expenses which according to section 32(11) are not 
deductible (in this Law: excess expenditures), or if it paid a levy under 
Chapter Six of the Arrangements in the State Economy (Law 226 
Amendments) Law 5749-1989, then it shall pay the Assessment Officer 
at the prescribed time an advance payment at the rates specified below 
of the excess expenditures which it incurred, and at the same time it 
shall submit to him a prescribed return and it shall also submit to him an 
annual return specifying and summing up all the excess expenditures 
which it incurred in that year, all as specified below: 
(1) a body of persons, to which section 3(g) applies – 90%; 
(2) any other body of persons – 45%; 
for purposes of this section: "body of persons" – exclusive of 
partnerships that do not include any partner that is a body of persons to 
which this section applies. 
(b) The provisions of subsection (a) shall not apply to amounts paid as 
work income from which the person who pays them or is responsible for 
their payment deducted tax under section 164. 
(c) If a body of persons did not make the advance payments said in 
subsection (a), or did not deliver a return under that subsection, or 
delivered a return but the Assessing Officer has reasonable grounds for 
believing that the return is not correct, then the Assessing Officer may – 
to the best of his judgment – assess the amount of advance payment 
which that body of persons must pay, and that assessment does not 
relieve it of any other obligation under this Ordinance; an assessment 
under this section shall be treated like an assessment under section 
145; the Assessing Officer may assess a person as said in this section 
during the period during which he may determine – to the best of his 
judgment – that person's chargeable income in the tax year in which he 
was under obligation to pay the advance. 
Set off against future tax 
181C. If a body of persons, to which the provisions of section 3(g) do not 
apply, 
made advance payments under section 181B for a certain tax year in an 
amount that exceeds the amount of tax which it must pay in that year, then 
the excess shall not be refunded to it; however, if its income from the same 
business or vocation will be liable to tax – including Land Appreciation Tax –
in subsequent tax years, then the excess amount shall be set off against the 
tax or the Land Appreciation Tax; the excess amount shall be adjusted at the 
rate of the index increase from the end of the tax year in which it was created
until the end of the tax year in which it was set off. 
Article Two: Times for Payment of Tax 
Payment on submission of return 
182. (a) When a body of persons submits a return under section 131 or an 
estimative return under section 133, it shall pay the amount of tax due 
from it according to that return. 
(b) The Minister of Finance may prescribe, by Order, in respect of other 
assessees – except for individuals at least 75% of whose income is 
chargeable income under section 2, paragraphs (2) or (5) – that the 
assessee to whom that Order applies shall, when he submits a return 
under section 131 or an estimative return under section 133, pay the 
amount of tax due from him according to that return. 
Payment after notice of assessment 227 
183. If a notice of assessment under section 149 was delivered to a person, then
he shall, within 15 days after delivery of the notice of assessment, pay the 
balance of tax due from him under it, and if he filed objection under section
150 – the balance of tax that is not in dispute. 
Payment after objection 
184. If an amended notice of assessment under section 152(a) or an Order under
section 152(b) was delivered to a person, then he shall – within 15 days after
delivery of the notice or Order – pay the balance of tax due from him under it,
and if he filed objection under section 153 – the balance of tax that is not in
dispute. 
Article Three: Interest and Fines 
Adjustment of payment after judgment 
185. If the decision of a District Court under section 156 or a decision of the
Supreme Court under section 157 was delivered to a person, then the 
following provisions shall apply: 
(1) if the assessee paid too much, then the excess amount shall be 
refunded to him, plus interest and linkage differentials, within their 
meaning in section 159A(a); 
(2) if the assessee paid too little, then the balance shall be paid within 
fifteen days after the decision is delivered, plus linkage differentials and 
interest as aforesaid for the period from the day the appeal was filed 
until judgment was given, unless the Court prescribed otherwise. 
Interest on postponement of times of payment 
186. The Assessing Officer may, if shown sufficient reason therefor, extend the
times prescribed under Article Two for the payment of all or of part of the tax,
or the times for payment of all or of part of the advance under Article One, for
a period he deems appropriate, on condition that the assessee pay linkage 
differentials and interest, within their meaning in section 159A(a), for the 
period of postponement. 
Payment of interest and linkage differentials 
187. (a) (1) In respect of amounts of tax for a certain tax year which were not
paid by the end of that tax year the assessee shall be charged 
linkage differentials and interest, within their meaning in section 
159A(a) for the period from the end of the tax year until the date 
of payment; for a person with a special assessment period the 
end of the special assessment period shall, for this purpose, take 
the place of the end of the tax year. 
(2) The provisions of this subsection shall also apply to tax debts 
under section 159A(c). 
(b) The provisions of subsection (a) shall not apply to a period, in respect 
of which linkage differentials and interest are owed under sections 
185(2) or 186. 
(c) (1) In respect of amounts of tax that should have been deducted, but 
were not deducted, or were deducted, but not transferred to the 
Assessing Officer at the time prescribed therefor, the person 
obligated to make the deduction shall be charged linkage 
differentials and interest, within their meaning in section 159A(a), 228 
for the period that begins on the fourteenth of the month before 
the day on which he should have, but did not transfer the 
amounts deducted, or on which he should have transferred, if he 
had deducted them on time, and until their transfer to the 
Assessing Officer; however, if the amount liable to deduction 
does not relate to a specific date and therefore is determined as 
a total for a certain period, then linkage differentials and interest 
shall be charged for the period that began in the middle of the 
said period. 
(2) If the person required to make the deduction proves that the 
person, from whose income he should have deducted the 
amounts that were not deducted, included the said amounts in a 
return of his income, then the date on which the amounts should 
have been transferred to the Assessing Officer shall be replaced 
by the expiration of the tax year to which the said return relates. 
(d) If advances in respect of excess expenditure should have been paid 
under section 181B and were not paid to the Assessing Officer on the 
prescribed date and if – had they been paid on time – they could not 
have been set off against advances paid or tax paid in respect of that 
tax year, then the debtor shall be charged linkage differentials and 
interest within their meaning in section 159A(a) for the period from the 
end of the tax year until the day of payment. 
Incentive for early filing of return and payment 
187A. (a) If an assessee paid any amount on account of tax due from him in 
respect of a certain tax year before the last date set in section 132 for 
submitting the return under section 131, then in respect of that amount 
he is entitled to exemption from linkage differentials and interest 
applicable thereto under section 187(a), as specified below: 
(1) on an amount paid until the end of the first month after the end of 
the tax year or special assessment period (hereafter in this 
section – tax year) – full exemption from linkage differentials and 
interest; 
(2) on an amount paid during the second month after the end of the 
tax year – exemption from half the linkage differentials and 
interest; 
(3) on an amount paid during the third month after the end of the tax 
year – exemption from one fourth the linkage differentials and 
interest. 
(a1) The Minister of Finance may, by Order, increase the rates of exemption 
said in subsection (a); 
(b) The relief under subsection (a) shall be computed first, and the relief 
under the closing passage of section 187(a)(1) shall be deducted from 
the balance of the linkage differentials and interest. 
(c) Repealed 
Fine for non-submission of return 
188. (a) If a person did not submit a return by the date set in section 132, 
then 
for each month of delay a fine of NS 200 shall be imposed on him; 
however, if a later date for the submission of the return was set for that 
person under section 133 (hereafter: delayed date), and if that person 
did not submit the return by the delayed date, then a fine of NS 400 
shall be imposed on him for each month of delay after the delayed date. 
(a1) If, in a return he submitted under section 131, a person did not specify 
229 
an act designated under the said section as tax planning that must be 
reported, then the Assessing Officer may impose on him a fine of NS 
500 for every month in which he did not report as aforesaid. 
(b) Repealed 
(c) If a person did not submit a return at the time set in sections 161 or 
171, then the Assessing Officer may impose on him a fine of NS 200 
for each month of delay. 
(d) If a person did not submit on time any of the returns prescribed for the 
purposes of sections 164 to 166, then a fine of NS 200 shall be 
imposed on him for each month of delay. 
(e) In this section, "month" – a whole month. 
(f) If a person, required to deduct tax at the source from amounts paid by 
him. does not at the prescribed time give to persons from whose 
payments tax was deducted the forms that certify the amounts paid to 
them and the tax deducted, then the Assessing Officer may impose on 
him a fine of NS 100 in respect of every person to whom the form was 
not delivered. 
(g) If a person did not submit on time a return under section 135(1), then a 
fine of NS 200 shall be imposed on him for each month of delay; 
however, if a date was initially set for delivery by that person of a return 
under section 135(1), and if subsequently on that person's application a 
later date was set for submission of the return (hereafter: delayed date), 
and if that person submitted the return after the delayed date, then a 
fine of NS 400 shall be imposed on him for each month of delay after 
the delayed date; 
(h) The amounts stated in this section, as they were on January 1 of the 
preceding tax year, shall be adjusted on January 1 of every tax year, at 
the rate of index increase during the preceding tax year; if income 
ceilings were adjusted in any month under section 120B(b), then the 
Director may adjust the amounts said in this section, as they were on 
January 1 of that tax year, as if they were income ceilings. 
(i) Repealed 
Saving of criminal responsibility 
189. (a) The payment of a fine under section 188 or the increase of tax rates
under section 191B shall not derogate from a person's criminal 
responsibility under this Ordinance. 
(b) If criminal action was brought against a person for non-submission of a 
return, then he shall not be charged a fine under section 188 for that 
offense, and if he has paid an aforesaid fine, then it shall be refunded 
to him; if a said criminal action was brought and the defendant was 
acquitted, then linkage differentials and interest, within their meaning in 
section 159A(a), shall be paid him from the day of the payment of the 
fine until its refund. 
Fine for delay in payment 
190. (a) (1) (a) If a person is more than seven days late in paying an 
advance which he must pay, or in paying part of it, then to 
the amount in arrears shall be added a fine in the amount 
of linkage differentials and interest within their meaning in 
section 159A(a) (hereafter: linkage differentials and 
interest), from the day set for the payment until the payment 
of the amount in arrears, or until the end of the tax year in 
respect of which the advance was required, whichever is 230 
earlier (hereafter: end of period of fine). 
(b) To a fine said in subparagraph (a) shall be added linkage 
differentials and interest from the end of period of the fine 
until the payment of the fine, and the fine shall be treated 
like a tax debt for purposes of section 195A. 
(c) Notwithstanding the provisions of subparagraph (a), if the 
date for the payment of an advance was postponed under 
section 175(f) and if a person paid an advance more than 
four days later than the date prescribed in section 175(a) or 
than the date prescribed under section 175(b), and if he did 
not pay the advance by the determining date set in section 
175(f), then the fine shall be added to the amount in arrears 
in accordance with the provisions of subparagraph (a). 
(d) If a person did not state the date for the payment of the 
advance, and if therefore the advance was set at a total 
amount for the entire period, then – for calculation of the 
fine under this section – the date for payment shall be 
deemed to be at the midpoint of the period in respect of 
which the advance was set. 
(2) If a person requested that the amount of his advance payments 
be reduced and it appears that the tax due according to the 
return filed by him exceeds the balance of advance payments 
after the reduction, then he shall pay on the amount of the 
reduction – but not on more than the difference between the tax 
due according to the return and the balance of the advance 
payments after reduction – linkage differentials and interest within 
their meaning in section 159A(a) from the middle of the tax year 
or special assessment period until the end of the tax year or 
special assessment period or, in respect of each payment, until 
the date of payment, whichever comes first; for this purpose, any 
amount paid on account of advance payments shall first be 
placed to the account of the advance. 
(3) For the purpose of reducing the amount of advance payments in 
a certain tax year, as said in paragraph (2), other than in respect 
of participation in the financing of research and development 
carried out by another person under section 20A(a) or under any 
other statute, and other than in respect of credit for contributions 
under section 46A or under any other statute, the tax from the 
payment of which the assessee was exempted because of the 
said deduction or credit shall not be taken into account in the 
calculation of tax in accordance with the return. 
(4) If an assessee failed to give notice of the beginning of business 
activity or its change in accordance with section 134, and if he 
consequently was not required to pay advances as said in section 
181, or if consequently the amount of his advance payments was 
not increased as said in section 180, then he shall be charged 
linkage differentials and interest in respect of the determining 
period, for the entire amount of advance payments which he 
owed, or for the amount by which the Assessing Officer was 
entitled to increase his advance payments, as the case may be; 
for this purpose: "determining period" – the period that begins in 
the middle of the period between the opening of the business or 
of its change and between the end of the tax year or the special 
assessment period, and that ends at the end of the said year or 231 
period, as the case may be. 
(5) For purposes of paying linkage differentials and interest, and for 
purposes of the order in which payments are credited under 
section 195A, linkage differentials and interest under paragraphs 
(2) to (4) shall be deemed a tax debt at the end of the tax year or 
special assessment period, as the case may be. 
(b) Repealed 
(c) Repealed 
(d) A fine imposed under this section shall not be deemed part of the tax 
paid for purposes of claiming relief under any of the provisions of this 
Ordinance. 
Fine for unlawful set-off of deduction at the source 
190A. If a person deducted from his advance payments a deduction at the source,
for which he does not have written certification or which was not deducted 
during the period permitted under section 177, then he shall be liable to a fine
of three times the amount of the improper deduction. 
Deficiency fine 
191. (a) In this section, "deficiency" – the amount by which the tax which an
assessee owes exceeds the tax payable by him according to his return 
under section 131 or, if he has not submitted such a return, the amount 
of tax determined under section 145(b), all as the case may be. 
(b) If a deficiency of more than 50% of the tax to which he is liable was 
found in respect of any assessee, and if he does not prove to the 
Assessing Officer's satisfaction that he was not negligent in making the 
return delivered by him or in the non-delivery of a return, then he shall 
be liable to a fine at the rate of 15% of the amount of deficiency. 
(c) If the Director or a person empowered by him for this matter has 
reasonable grounds for believing that the deficiency was created 
willfully and with the assessee's intent to evade payment of tax, then 
double the fines specified in subsection (b) shall be added to the 
amount of tax to which the assessee is liable. 
(c1) If a final assessment that can no longer be appealed includes – in 
respect of an act which under section 131(g) was designated tax 
planning that must be reported – the determination that it must be 
ignored under the provisions of section 86, then the assessee shall be 
liable to a fine at the rate of 30% of the shortfall created by the said tax 
planning; when a said fine is imposed, then no fine shall be imposed in 
respect of that shortfall under the provisions of subsections (b) and (c). 
(d) For purposes of sections 149 to 152, the addition of a deficiency fine 
under this section shall be treated like an assessment. 
(e) Linkage differentials and interest shall be added to a fine imposed 
under subsections (b) or (c) after February 28, 1985, from the end of 
the tax year in respect of which the return was submitted or the 
assessment made under section 145(b), or from February 28, 1985, 
whichever is later, and until the day the fine is paid, and the fine shall 
be deemed a type of debit charge for the purposes of section 195A. 
Fines for failure to deduct 
191A. If a person without reasonable justification fails to deduct tax which he 
is 
required to deduct under section 161, 164 or 170, then he shall be liable to a
fine at the rate of 15% of the amounts which he did not deduct. 
232 
Increase of tax rates for not keeping books 
191B. (a) If an assessee is required to keep account books for a certain tax 
year 
or part of it and did not keep them, or he kept them only during part of 
the period during which he was obligated to keep them, or if he did not 
base his return on account books, then the tax to which he is liable for 
that year shall be increased by 10% of the amount of the chargeable 
income in respect of which he was required to keep accounts, and in 
every subsequent year in which he does not keep account books as 
aforesaid the tax shall be increased by 20% of the amount of the 
aforesaid income; however, if a person was first required to keep books 
in a certain tax year, but first began to do so after the date on which he 
was required to begin, then the said additions shall only apply to the 
period during which he was required to keep books and did not do so. 
(b) If an assessee was charged an addition to tax for a certain tax year, 
then the advance payments for the year during which the assessment 
for that certain tax year is made shall be increased by 20%, if the 
addition to the tax is 10%, and by 40% if the addition to the tax is 20%, 
but if the tax was also increased for the tax year according to which the 
advance payments were fixed, then the rate of increase of the advance 
payment shall be reduced by twice the rate of addition to the tax; this 
provision shall not apply if the assessee proves, to the Assessing 
Officer's satisfaction, that – in the tax year in which the aforesaid 
assessment was made – he kept account books or was not required to 
keep them. 
Fine for false record 
191C. If an assessee is required – under directions from the Director by virtue 
of 
section 130 – to record identifying particulars of a purchaser who pays cash,
based on a document produced by him, and if he does not record them or 
records incorrect particulars, then a fine of 5% of the amount of the sale in
respect of which he violated a said direction shall be imposed on him, or a 
fine of NS 12,900, whichever is more. 
Director's authority to decrease interest or fine 
192. The Director may reduce the rate of interest or of linkage differentials 
and 
interest under sections 186, 187 and 190, and the amount of fine under 
sections 188, 190, 190A, 191A and 191C, or waive them completely, if it is 
proved to his satisfaction that the delay which caused the liability to pay was
not caused by any act or omission that depended on the assessee's will; the 
Director may, at his absolute discretion, reduce or waive as aforesaid, if it is
proven to his satisfaction that the assessee did not know the exact amount of
tax due from him before he filed the return; however, the Director may not 
reduce the amount of interest or linkage differentials and interest under 
sections 186, 187 and 190 only because the assessee duly made his 
advance payments or because tax was duly deducted from him or he paid the 
tax due from him in accordance with his return when he submitted it. 
Time for paying interest, linkage differentials or fine 
192A. The time for the payment of interest, linkage differentials and interest 
or fines, 
which the assessee must pay under the provisions of this Ordinance, shall be 
within 30 days after he was sent notification of that obligation. 
233 
Article Four: Enforcing Payment 
Assessing Officer may enforce payment 
193. If a person is obligated to pay any amount under this Ordinance, then the
Assessing Officer may enforce its payment as provided hereafter or under the 
Taxes (Collection) Ordinance, and the provisions of that Ordinance, except 
for section 12 there, shall apply to the collection of any said amount as if it
were a tax, within its meaning in that Ordinance; however, when the 
Assessing Officer is not the District Officer, then the Assessing Officer shall
forward to the District Officer of the district in which the assessee resides or
carries on his business a certificate signed by the Assessing Officer that 
specifies the amount of arrears due from the assessee, and upon receipt of 
that certificate the District Officer shall enforce payment under the provisions
of the Taxes (Collection) Ordinance that apply to the collection of a said 
amount. 
Collection of tax in special cases 
194. (a) If the Assessing Officer has reason to suspect that the tax on a 
certain 
income will not be collected because a certain person intends to leave 
Israel, or because of any other reason, then he may – 
(1) if that person already was assessed in respect of that income or 
is under obligation to make advance payments on it – demand by 
written notice that that person immediately provide collateral, to 
the Assessing Officer's satisfaction, for payment of the tax 
assessed or of the advance payments he must make; 
(2) if that person has not yet been assessed as aforesaid – assess 
him according to the amount of income of which a return was 
made or, if that person has not made a return or has made a 
return which does not satisfy the Assessing Officer, in an amount 
which the Assessing Officer deems reasonable; 
(3) if that person is not yet obligated to make a return of that income 
– require him by written notification to prepare a return 
immediately, and thereafter the Assessing Officer may act as said 
in paragraph (2). 
(b) If an assessment was made under subsection (a)(2), then the 
Assessing Officer shall make notification of it, and all the tax assessed 
under that assessment shall be paid immediately upon delivery of that 
notification. 
(c) If the assessee did not pay the tax or did not provide the collateral 
according to subsection (a)(1), then the competent Court may, on the 
Assessing Officer's application, make an Order even in the assessee's 
absence – 
(1) to stay his departure from Israel; 
(2) to attach his property. 
(d) If an assessee paid the tax or provided collateral under this section, 
then he is entitled to file objection and appeal under sections 150 to 
158, and the amount paid by him shall be corrected according to the 
results. 
Action by Assessing Officer 
195. An action may be brought by the Assessing Officer in his official capacity 
for 
tax and all costs, and it may be recovered in a competent Court from the 
person who owes it, as if it were a debt to the Government of Israel, and it 
may be sued for and recovered by the means prescribed in section 193. 234 
Article Five: Crediting an Assessee's Payments 
Crediting payments 
195A.(a) When a person pays any amount on account of a tax debt, a 
proportional part of the amount paid shall be credited against each type 
of debit in that tax debt, in the proportion of that type of debit to the 
entire tax debt; in this context: 
(1) if the person did not specify the amount paid as being on account 
of his debt as assessee or as deductor, the amount shall be 
credited against his debt as deductor; 
(2) a tax refund, which under the Tax Set Off Law 5740-1980 is set 
off against a tax debt, and an amount collected under the Taxes 
(Collection) Ordinance or in any other way shall be treated like an 
amount paid by that person. 
(b) (1) If a person paid an amount on account of a tax debt which he 
owes as an assessee, without specifying the year of the debt, 
then the amount shall be credited against his tax debts as 
assessee according to the years in which they were created, 
beginning with the earliest tax year; 
(2) if a person paid an amount on account of a tax debt he owes as a 
deductor, then the amount shall be credited against his tax debts 
as deductor in the order in which they were created, beginning 
with the earliest one. 
(c) In this section – 
"tax debt" – each of the following: 
(1) the total amount of all types of debits owed by a person under 
this Ordinance, as assessee for a certain tax year; 
(2) the total of amounts of all types of debits owed by a person under 
this Ordinance as deductor, in respect of any payment which he 
paid to another person; 
"type of debit" – each of the following: tax, interest, linkage 
differentials. 
Article Six: Monetary Composition in Respect of 
Online Returns 
Monetary composition 
195B. Notwithstanding the provisions of Article Three, if the Director has 
reasonable 
grounds to assume that an online return was not submitted up to the date 
said in section 132 or 166, as the case may be (in this Article: violation), 
then 
he may impose a monetary composition on the violator in the amount 
specified below in respect of each whole month of delay in submitting the 
return; 
(1) if an individual did not submit an online independent return under 
section 131(b2) – NS 1,000; 
(2) if an employer did not submit and employer's online return or if a 
deductor did not submit a deductor's online return – NS 1,500. 
Demand for monetary composition and its payment 
195C. Monetary composition for a violation under section 195B shall be paid at 
the 235 
Director's demand on a form he prescribed (hereafter: payment notice) within 
thirty days after the payment notice was dispatched; the payment notice shall
specify, inter alia, particulars of the violation for which the monetary 
composition was imposed and its amount, and it shall also include information
on the right to present arguments to the Director, as said in section 195D. 
Writ of arguments 
195D. (a) An individual, an employer or a deductor to whom a payment notice 
was sent may, within thirty days after dispatch of the said notice, submit 
his written arguments on imposition of the composition and its amount 
to the Director in writing (in this section: writ of arguments); to the writ of
arguments shall be attached an affidavit in support of the facts 
specified in it. 
(b) When an individual, employer or deductor has submitted a writ of 
arguments to the Director, then the Director shall decide on the basis of 
the writ of arguments and of the affidavit whether to leave the payment 
notice in effect or cancel it, and he may – in order to reach the said 
decision – summon the person who submitted the writ of arguments to 
a hearing before him; a notice of the Director's decision under this 
subsection shall be sent to the person who submitted the writ of 
arguments. 
(c) Submitting the writ of arguments under this section shall not stay 
payment of the monetary composition at the time said in section 195C. 
(d) If the monetary composition was paid and the Director decided under 
this section to cancel the payment notice, then the monetary 
composition shall be refunded with linkage differentials and interest 
within their meaning in the Interest and Linkage Adjudication Law 5721-
1961 (in this Article: the Interest Adjudication Law) from the day of its 
payment until the day of its refund. 
Updating the amount of monetary composition 
195E. (a) Monetary composition shall be at its updated amount on the day the 
payment notice is dispatched, and if a petition was brought and the 
Court that heard the petition ordered its payment to be stayed – at its 
updated amount on the day of the decision on the petition. 
(b) The amount of monetary composition shall be updated on January 1 of 
each year (in this section: the updating day) at the rate of increase of 
the index known on the updating day over the index that was known on 
the updating day of the preceding year, and in respect of the first 
updating day – over the index that was known on January 1, 2008; the 
said amount shall be rounded to the nearest amount that is a multiple 
of NS 10. 
(c) The Director shall publish the updated amount of the monetary 
composition in a notice in Reshumot. 
Linkage differentials and interest 
195F. If monetary composition was not paid on time, then linkage differentials 
and 
interest shall be added to it, within their meaning in the Interest Adjudication
Law, for the arrears period up to its payment (in this Article: arrears 
supplement). 
Collection 
195G. The Taxes (Collection) Ordinance shall apply to collection of the monetary
composition and of the arrears supplement. 236 
Reserving criminal liability 
195H. (a) Payment of monetary composition shall not derogate from the 
individual's, employer's or deductor's criminal liability for the violation. 
(b) If an indictment under section 216(4) or (4a) was brought against an 
individual, employer or deductor for a violation, then he shall not be 
obligated to pay monetary compensation for it, and if he paid, then the 
amount paid shall be refunded to him with the addition of linkage 
differentials and interest, within their meaning in the Interest 
Adjudication Law, from the day of its payment until the day of its refund. 
Petitioning the Administrative Affairs Court 
195I. (a) Petitioning the Administrative Affairs Court against the imposition of
monetary composition under this Article, in accordance with section 
32(5) of the Administrative Affairs Courts Law 5760-2000, shall not stay 
payment of the monetary composition, except with the Director's 
consent or if the Court so ordered. 
(b) If a petition said in subsection (a) was accepted after the monetary 
composition was paid, then the monetary composition shall be 
refunded with the addition of linkage differentials and interest, within 
their meaning in the Interest Adjudication Law, from the day of its 
payment until the day of its refund 
CHAPTER THREE: DOUBLE TAXATION RELIEF 
Article One: Reciprocal International Agreement 
Order that gives effect to agreement 
196. (a) When the Minister of Finance has given notice by Order, that an 
agreement specified in the Order was concluded with a certain state to 
afford double taxation relief on income tax and on every other tax of a 
similar character imposed by the Laws of that state (hereafter: 
reciprocating state) and that it is expedient to give that agreement effect 
in Israel, then that agreement (hereafter: agreement) shall have effect 
in relation to income tax, notwithstanding any provision of any statute. 
(b) An Order made under this section may be revoked by a subsequent 
Order. 
(c) In this section, AState@ – including areas outside Israel that are not a 
State, enumerated in Schedule One AA1@. 
Obligation of secrecy in case of agreement 
197. When an agreement has been given effect as said in section 196, then the
obligation to maintain secrecy imposed by section 234 shall not prevent 
disclosure – to an authorized officer of the reciprocating state – of any 
information that is to be disclosed under the agreement. 
Power to make regulations 
198. The Minister of Finance may make regulations for implementation of the 
provisions of an agreement. 
237 
Article Two: Determining Amount of Relief 
Definitions 
199. In this Chapter – 
"income tax" – exclusive of companies tax; 
"Israel taxes" – income tax and companies tax; 
"foreign taxes" – taxes payable by an Israel resident to tax authorities of a
state other than Israel, on income produced or accrued in that state, including
taxes payable to states that are parts of a federal state or to regional 
authorities that are parts of that state, calculated as percentages of the 
income and exclusive of municipal taxes; 
"foreign income" – income produced or accrued abroad; 
"foreign income from a certain source" – foreign income, classified by the 
sources of income prescribed in section 2, in Part Five or in Part Five "C", 
less expenses that may be deducted from them and losses that may be set 
off against them, all in accordance with the provisions of the Ordinance. 
Provisions on crediting double taxation 
200. (a) Foreign taxes paid on foreign income that is chargeable to tax in 
Israel, 
shall – translated into new shekel amounts – be allowed as credits 
against Israel taxes under this Ordinance, in accordance with the 
provisions of this Article. 
(b) Israel taxes shall be credited in a certain tax year only if the person 
whose income is chargeable to those taxes was an Israel resident in 
that tax year. 
(c) The Director may prescribe rules for the implementation of this Article 
and rules on the matter of returns. 
Deduction of foreign taxes 
201. (a) Foreign taxes paid in respect of foreign income that is tax exempt in
Israel shall not be deducted. 
(b) The relief granted in respect of dividends under section 163 shall be 
deemed a reduction of the amount of tax which applies to that dividend 
under the Ordinance. 
Credit against companies tax precedes credit against income tax 
202. If an agreement permits credit against companies tax and income tax, then
the amount of credit shall be used first to reduce companies tax on that 
income and – to the extent that all of it cannot be used for that purpose – it
shall be used to reduce income tax on it; if the agreement allows credit only
against income tax, then section 201 shall be construed as if it said "income
tax" instead of "Israel taxes". 
Amount of credit against companies tax 
203. (a) The amount of credit against companies tax, to which an Israel resident
body of persons is entitled under the provisions of this Article in respect 
of foreign income from a certain source shall not exceed the amount of 
companies tax to which it is liable on that income. 
(b) If the foreign income includes dividends, in respect of which the 
assessee company, as defined in section 126(c), requested that it pay 
tax at the rate prescribed in section 126(a), or if – under an agreement 
to prevent double taxation – the foreign taxes paid on that dividend and 
which were not imposed directly must be taken into account as credits, 238 
then the grossed up dividend shall be added to all of the company's 
income and credit shall be given in the amount of the foreign taxes that 
were not imposed directly on that dividend, in addition to the foreign 
taxes; the total credit in this section shall not exceed the amount of tax 
that applies to the said dividend. 
(c) In this section – 
"foreign taxes not imposed directly" – taxes paid by a foreign 
resident body of persons on income which, after the payment of tax, 
was distributed as a dividend; 
"grossed up dividend" – the amount of income from a dividend 
received after tax was deducted at the source, plus the tax deducted at 
the source, plus foreign taxes not imposed directly. 
Amount of credit against income tax 
204. (a) The amount of credit against income tax to which an Israel resident 
individual is entitled under the provisions of this Article in respect of 
foreign income from a certain source, which is ordinary income, shall 
not exceed the credit ceiling in respect of that income. 
(b) The amount of credit against income tax to which an Israel resident 
individual is entitled under the provisions of this Article on foreign 
income from a certain source, which is chargeable to tax at a special 
rate, shall not exceed the amount of tax that applies to that income in 
Israel. 
(c) In this section – 
"ordinary income" – chargeable income, on which no special tax rate 
is imposed; 
"income ratio" – the ratio obtained by dividing the amount of foreign 
income from a certain source that is ordinary income, by the total 
amount of ordinary income; 
"special tax rate" – a tax rate that applies in Israel and is different from 
the tax rate prescribed in section 121; 
"credit ceiling" – the amount obtained by multiplying the income ratio 
by the amount of income tax on the individual's total ordinary income 
before any credit under this Article was granted. 
205. Repealed 
Excess credit in a tax year 
205A. (a) If the amount of foreign taxes paid in respect of foreign income from 
a 
certain source exceeds the amount of credit granted in its respect 
against Israel taxes (in this section: excess credit), then the assessee is 
entitled to subtract the excess credit from tax to which he will be liable 
in respect of income produced abroad from the same source in the 
following five years, one after the other, adjusted at the rate of the index 
increase from the end of the tax year in which it was created to the end 
of the tax year in which it was subtracted; the excess credit shall be 
subtracted in accordance with this section, subject to the provisions of 
this Chapter, mutatis mutandis. 
(b) Notwithstanding the provisions of subsection (a), if an excess credit 
was created because of the set off of a loss that stems from foreign 
income from a certain source against foreign income from another 
certain source, then in the five coming years, one after the other, it may 
also be subtracted from the tax on foreign income from the source from 
which the said loss stems, adjusted as said in that subsection. 
239 
Rules for computing income for purposes of credit 
206. When calculating foreign income that is chargeable to tax in Israel, no 
deduction from it shall be allowed in respect of foreign taxes. 
Credit for tax on dividend in special cases 
207. If the agreement provides, in respect of certain categories of dividends, 
but 
not in respect of others, that foreign taxes not imposed on them directly or by
deduction are to be taken into account for purposes of credit against Israel 
taxes on them, and if a dividend paid is not of the said specific categories,
then – if the dividend was paid to a company which directly or indirectly 
controls at least half the voting power in the company that pays the dividend –
the credit shall be allowed as if the dividend belonged to one of those specific
categories. 
Credit for dividend 
207A. (a) If an Israel resident body of persons received a dividend from a body 
of 
persons, which is considered an Israel resident only because its 
business is controlled and managed from Israel (in this section – the 
other body) and if tax from the dividend was deducted at the source in 
the foreign state, then the other body shall be entitled to credit in the 
amount of the tax deducted at the source as aforesaid, against the 
companies tax that applies to it; the amount of the credit shall not 
exceed the companies tax that applies in that tax year, but an unused 
balance of the credit may be used against companies tax that will be 
imposed on the other body in the following five years, one after the 
other. 
(b) If an Israel resident individual received a dividend from the other body 
and tax at the source was deducted in the foreign state, then the 
individual shall be entitled to a credit in the amount of tax deducted at 
the source, against the tax that applies to his income from the said 
dividend, all subject to the provisions of this Chapter. 
Credit for foreign taxes 
207B. Foreign tax can be credited against Israel tax that applies in a tax year 
only if 
it was paid in the foreign state no later than 24 months after the end of that
tax year, except for tax that was supposed to be paid on unpaid profits, as 
defined in section 75B; foreign tax paid in the foreign state after the said 
period may be deducted in the tax year in which it was paid in the foreign 
state, against tax due in Israel on foreign income from the same source, and 
the provisions of this Chapter shall apply to it, mutatis mutandis; in the case 
of 
disagreement on the amount of the credit, the applicant for the credit has the
right of objection and appeal, as said in sections 150 and 153, as part of an
objection and appeal against the assessment made for him. 
Credit for foreign taxes – employee of a certain employer 
207C. If an individual has income, the place of production of which is in Israel 
only 
because of the provisions of section 4A(b)(1), then for purpose of the 
provisions of this Article the individual's income shall be deemed foreign 
income and the taxes paid to tax authorities in the foreign state in respect of
that income shall be deemed foreign tax. 
Restriction on credit 
207D. When a loss from a controlled business has been set off against income in
Israel, as said in section 29(2)(c) or (e), then no credit shall be given under 
240 
this Chapter against Israel taxes, to which the Israel resident is liable in 
respect of chargeable income he had from a business abroad during the two 
years before the tax year in which the loss was set off and in the five years
thereafter, one after the other, up to the amount of the loss set off as 
aforesaid. 
Waiver of credit 
208. Credit against Israel taxes to which a person is liable in a tax year shall 
not be 
allowed, if he requested that no credit be given against his income in that 
year; if he so requested, then the provisions of section 205A shall not apply.
209. Repealed 
Error in calculating credit 
210. If the amount of credit is found to have been set too high or too low, in
consequence of a change in the amount of tax payable in Israel or abroad or 
because of the provisions of section 207D, then no provision of any statute 
that limits the time for making assessments or claims for relief shall apply to
an assessment or claim to which the change gave rise, if it was made not 
later than two years after the assessments, changes and other decisions – in 
Israel or abroad – which matter in respect of the question whether any credit
is to be given and what it shall be. 
Article Three: Miscellaneous Provisions 
Definitions 
211. In this Article – 
"double taxation relief" – any credit for income tax abroad, allowed for 
purposes of income tax under this Ordinance, including any credit or relief 
taken into account in determining the net Israel rate to be levied on dividends
received; 
"rate of relief" – the rate, which is the rate of the excess tax deducted from
the dividend, over the net Israel rate. 
Effect of relief on set off and refund 
212. When the tax payable by a company is affected by double taxation relief, 
then 
the amount to be set off under section 163 or to be refunded under section 
160 in respect of the tax deducted by the company from any dividend paid by 
it shall be reduced according to the following rules: 
(1) If the recipient of the dividend is not liable to tax on it, then the 
reduction shall be in an amount equal to the tax on the grossed up 
dividend, at the rate of relief applicable to it; 
(2) if the rate of tax to which the recipient is liable in respect of the 
dividend 
is less than the rate of relief applicable to it, then the reduction shall be
in an amount equal to the tax on the grossed up dividend, calculated at 
the difference between those two rates. 
Place of dividend in scale of income 
213. For purposes of section 212: 
(1) if the income includes one dividend said in section 212, then it shall be
deemed to be in the highest bracket of the income; 
(2) if the income includes several aforesaid dividends, then any dividend, 241
the net Israel rate of which is lower than that of another dividend shall 
be deemed to be in a higher bracket in the scale of income; 
(3) if tax a dividend is chargeable at different rates on its different parts, 
or 
if the tax is chargeable on one part of a dividend and not on another 
part of it, then each part shall be treated like a separate dividend. 
Double taxation relief on a resident's foreign income 
214. (a) In respect of an Israel resident's income, the source of which is 
abroad 
and on which income tax or a similar tax is charged at its source, the 
Minister of Finance may, by Order, grant double taxation relief by 
exempting the income from paying all or part of the tax, as shall be 
specified in the Order. 
(b) The provisions of this section shall not derogate from the powers under 
section 196.