What counts as passive income for Israel's CFC rules?

Under Section 75B of the Income Tax Ordinance, passive income includes dividends received from third parties, interest on loans or deposits, rent from real property or equipment, royalties from intellectual property, and capital gains from assets that generate passive income. If passive income exceeds 50% of the foreign company's total income, the passive income portion is subject to CFC taxation. Genuine active trading income from manufacturing, services, or commerce does not count as passive income, provided the business has real commercial substance.