Tax & Finance
Can I get a foreign tax credit against Israeli CFC tax for taxes paid in the CFC's home country?
Yes. Israel grants a foreign tax credit under Section 200 of the Income Tax Ordinance for taxes actually paid by the CFC in its home country on the same income deemed distributed in Israel. The credit is limited to the Israeli tax that would otherwise be owed. If the effective foreign tax rate exceeds the Israeli rate, the surplus credit generally cannot be carried forward. Always verify the applicable double tax treaty, as treaties with specific countries can modify how credits apply to deemed dividends.
From the full guide: Controlled Foreign Company (CFC) Rules in Israel: What Olim and Investors Must Know
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Get a Free Consultation with Adv. Eli ShimonyPrepared under the direction of Adv. Eli Shimony, Eli Shimony Law Office · Editorial policy
Get a Free Consultation with Adv. Eli ShimonyPrepared under the direction of Adv. Eli Shimony, Eli Shimony Law Office · Editorial policy