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How do I object to and appeal an Israeli income tax assessment?

Through a two-stage statutory route with a hard 30-day entry point. Section 150 of the Income Tax Ordinance [New Version] 5721-1961 lets a taxpayer file a written objection (hasagah) with the assessing officer within 30 days of the assessment notice. The officer must then reach a reasoned decision under Section 152, and failing agreement the taxpayer may appeal to the District Court under Section 153. Missing the 30-day window generally makes the assessment final and unchallengeable, whatever its merits. Extensions exist but are discretionary and must be requested rather than assumed.

The Ordinance builds a ladder. An assessing officer (pakid shuma) may issue a best-judgment assessment under Section 145 where a return is missing, incomplete or not accepted. The taxpayer's response is the Section 150 objection, which must be in writing and set out its grounds. Section 152 governs what follows: the parties may agree a revised figure, and failing agreement the officer issues a determination. That determination must generally come within one year of the objection, and a failure to decide in time can result in the objection being accepted by default. Section 153 then gives a right of appeal to the District Court sitting as a tax court, where the hearing is a genuine rehearing on the evidence.

Non-residents meet this most often after a property sale, a share disposal, or a rental-income review in which the Authority disputes the figures or the taxpayer's residency status. Two practical points dominate. The burden of proof in a Section 153 appeal usually sits with the taxpayer where the assessment rests on books the Authority rejected, so contemporaneous documentation counts for more than argument. And an objection does not suspend collection: the Authority can pursue the assessed sum while the dispute runs. Real estate taxes follow a parallel but separate track with their own window and appeals committee, so confirm which regime applies before responding, alongside our guide to filing an Israeli tax return.

⚖ In Practice
  • Governing law: Sections 145, 150, 152 and 153, Income Tax Ordinance [New Version] 5721-1961
  • Competent authority: the assessing officer (pakid shuma) at the relevant Israel Tax Authority office, then the District Court sitting as a tax court
  • Deadline: 30 days from service of the assessment to file the Section 150 objection, in writing and with grounds
  • Officer's deadline: a Section 152 determination must generally issue within one year of the objection
  • Separate track: betterment and purchase tax assessments are objected to under the Land Taxation (Appreciation and Acquisition) Law 5723-1963 and heard by a Real Estate Taxation Appeals Committee
  • Collection: an objection does not stay collection; a payment arrangement or stay must be sought separately

From the full guide: Filing Your Annual Income Tax Return in Israel: A Guide for Foreigners and New Residents

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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

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