What percentage of ownership triggers Israel's CFC rules?

Israeli residents must collectively hold more than 50% of any one of four rights in a foreign company: voting rights, right to profits, right to appoint directors, or right to assets on liquidation. A single Israeli resident can trigger CFC status on their own. Ownership is measured on a direct and indirect basis, so shares held through trusts, partnerships, or intermediate holding companies are all counted. There is no minimum personal ownership threshold — even a small Israeli-resident shareholder is subject to the rules if the 50% collective test is met.