Tax & Finance

Does the 10-year Oleh tax exemption protect me from Israel's CFC rules?

Partially. The 10-year exemption under Section 14(a) of the Income Tax Ordinance historically shielded new immigrants from being taxed on foreign-source income, and the ITA has generally accepted that this covers deemed dividends from CFCs during the exemption window. However, from 2026 onward, new immigrants must still file Form 150 to report CFC holdings even if no Israeli tax is currently owed. The 2026 reforms removed the reporting exemption that previously allowed Olim to avoid disclosure altogether.

From the full guide: Controlled Foreign Company (CFC) Rules in Israel: What Olim and Investors Must Know


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