Equities - rates, eligibility, availability of relief etc. – Israel

15.11.2024

Withholding tax

Standard rate on equities

0% - 25%

Holding restrictions

Yes

A dividend distribution on Israeli equities in Clearstream Banking may comprise various components, each subject to its own rate of withholding tax, that together constitute the total distribution payment.

The withholding tax rate may therefore be a weighted average of the different rates based on the different sources of income that make up the dividend distribution, as follows:

Component

Non-resident withholding tax rate

Regular income:

Dividend a

25% or DTT rate

Approved Enterprise: b

Approved Enterprise distributions may be subject to different tax rates and are subject to individual tax authority approval of a reduced tax rate that will be specified per distribution.  

REIT funds:

Rate dependent on source of income

  1. On a minimum ILS 600mn in certain areas if certain requirements are met.
  2. The foreign investor holding in capital formation must be at least 25%.

--------------------

a. Effective 1 January 2022, Oil and Gas Limited Partnership distributions from Israeli equities are treated as regular dividends subject to 25% withholding tax by default. Prior to this date, such distributions were not treated as regular dividend distributions for tax purposes and 0% withholding tax was applied for non-resident beneficial owners.

b. Dividends of an Israeli company derived from the income of an Approved Enterprise, if distributed either during the benefits period or during the twelve following years (or without limitation as to their distribution date, where paid by a foreign investment company out of its Approved Enterprise profits) shall be subject to a 15% dividend withholding tax.

The Approved Enterprise preferential rate of withholding tax may be subject to a possible reduction under tax treaties that make specific reference to the application of the Law for the Encouragement of Capital Investments.

Clients are reminded that it is their responsibility to ensure that final beneficial owners are eligible for the tax rate applied, including the Clearstream Banking default rates.

It is the client's responsibility to comply with this obligation. Neither Clearstream Banking nor its local depository has any direct or indirect liability towards the Israeli authorities in this regard.

Availability of relief through Clearstream Banking