Tax Ruling (Pre-Ruling) Support

Step one: whether to file at all

This is the question we ask before anything else, and quite often our answer is no. A pre-ruling costs time and a fee, requires full disclosure, and sometimes draws attention to an issue that would have passed quietly.

Our assessment starts with three questions:

1. How much tax is genuinely at stake relative to the cost and time of the process;
2. How strong your position is — where it is clear and unambiguous, it is sometimes better simply to report on that basis and be ready to defend it;
3. Whether an outside party requires certainty — an investor, a buyer or a bank. When the transaction itself depends on the answer, the equation changes.

If the conclusion is not to file, we will say so — and propose the alternative: an internal opinion, supporting documentation, or preparation for a future assessment hearing.

Building the factual basis

A tax ruling is worth exactly as much as the disclosure that preceded it. A material particular omitted — even in good faith — allows the Director to retract the ruling, at precisely the moment you are relying on it.

So this is the heaviest stage: a full mapping of the facts, evidence, agreements and drafts, and a structured assessment of what is material and what is not. This is also where facts sometimes emerge that change the merits of the whole exercise — and better that they emerge with us.

The drafting — and why it is not technical

A ruling request is not merely a description of facts. It presents a reasoned position: what outcome is sought, what it rests on, and how it sits with the language of the law, its purpose and the Authority's earlier positions.

A request framed as an open question invites an open answer. A request framed as a grounded position sets a starting point — and that is what gets discussed.

The argument stage — the part not to give up

Before the ruling is given, the applicant has the right to present their arguments. This is the stage at which the Authority's leaning becomes apparent, and where influence is still possible — clarifying, presenting a further fact, and sometimes narrowing the scope of the question in order to obtain a positive answer rather than a sweeping negative one.

Representation at this stage is led by the founding partners — former senior assessment inspectors, who know from the other side how a request is weighed and what persuades. On hi-tech, encouragement-law and international taxation matters it is led by CPA Amir Gonen, former Head of the Tax Division at the Innovation Authority and a former senior inspector in international taxation.

CPA Hanoch Hager  ·  CPA Tzvika Alperowitz  ·  CPA Amir Gonen

And after the ruling

A tax ruling is not a document to be filed away. It usually arrives with conditions, time limits or other restrictions — and failing to meet them voids it. We translate the ruling into a practical task list, and support its implementation in the filings and the books throughout the period it covers.

← Read our full guide: tax rulings — the mechanism, deadlines and traps

The information on this page is general and does not constitute professional advice. Whether to apply and which route to take are assessed on the merits of each case.