1. Limited Liability Company
The main field of activity:
Commercial activities in Israel to means a company owned by a citizen of Russia (or any other state), interested in setting up a company in Israel. The company is flexible and the most accepted tool to own and manage property and funds in Israel.
The most effective and accepted method of acquisition of the property is using, a loan which provides shareholder of the company, and that the company, in turn, acquires the property. Advantages: Limited liability of the shareholder in relation to the debts of the company, as the owner of the company itself a legal entity recognized by law individuals (this advantage is important primarily in the conduct of business). The possibility of money and property to the designated officer. The ability to quickly and easily replace the identity of the director. The accounts of the company: · At least once a year of filing the declaration to the tax authorities (depending on the size of business). · Submission of the annual reference about the status of the state registrar of companies. · Submission of applications to the registrar of companies, in case of change activity of the company, changes in the number of shares, transfer of shares, changes in the statute of the company, increasing capital, changes in corporate structure, changes in details, the appointment and change of directors, changing the composition of the company's management, change her name, etc. Taxation in Israel: · Tax profit in Israel (if available) - 26.5%. · The tax on dividends from the profit of the company will amount to - 30% (in the case of sole ownership of shares that one shareholder). If a company obtains a loan from the owner or returns it holder, this step is not profitable and is not subject to tax (but the interest accrued on the loan is a profit and is subject to the tax). 2. Asset management in Israel - Trust (Neemanut): General description basis of trust management in Israel borrowed from the British legislation. In accordance with the Law of the Trust Deed of 1979 ("Hawk and Neemanut"), the Trust is created when the contract between the principal and the trustee under the Trustee receives at its disposal assets of the principal undertaking to manage this property in the interests of the principal. Thus, : · Control and management of the property is transferred into the hands of a trustee. · Trustee is obliged to act in the interests of the principal, according to the terms of the trust and the purposes for which it was created. Asset management, according to the Israeli law is not a legal entity but merely the legal form of relations between two (or more) individuals. Thus, the Trust does not require formal education and record in government, and is governed by the agreement on the establishment of a trust, defining the status of the principal and the trusted party, the status of the property and describing in detail their legal relationship. The very fact of signing the principal document is the will to give up its property management and pass it to the control of a trustee, who will act in favor of the former. However, for tax purposes, the base of the Trust requires the application and open a separate case in state tax authorities. Thus, the tax authorities statements of the Trust are conducted in the name of the trustee, but apart from his personal statements. In practice, often taken to register a separate company to manage the trust property. Thus the property of the trust more effectively separated from the personal assets of the trustee and conducted a separate legal entity, the founder of which is the trustee. The types of property to transfer a trusted owner: There are no restrictions on the types of assets can be transferred to these kinds of trust: cash, real estate , shares in companies, intellectual property rights, investment packages, bank notes and bonds, insurance policies, etc. The actors in the establishment of the Trust · The Trustee (the settlor) (Settlor) - the person who initiates the creation of the trust, and trust their personal property trustee. The trustee (Trustee) - the person receiving at its disposal the property of the principal accepting commitments manage this property solely for the benefit of the beneficiary. Director of Asset Management Trust - as indicated above in Israel, there is the practice of registering a separate company for management of trust property . Management of such companies requires a director who can make himself the trustee or any other person, the choice of the settlor. The beneficiary (Beneficiary) - the person in whose favor the management of the property is conducted. Principal may be the same and the beneficiary, thus entrusting their property to their advantage. The tread Trust (Protector) - there is the possibility of appointing a protector, to monitor the activities of the trustee, limiting their actions, the appointment of another trustee, etc. All the above-mentioned persons may be both residents of Israeli and foreign residents, at the choice of the settlor. Application and · Ability to adapt the Trust to the needs of the beneficiary, the group of beneficiaries of the family (for example, transfer of ownership between generations). · Allows to concentrate the ownership of different objects scattered around the world in one place, in the hands of companies registered in Israel and operating as a property management company of the Trust (the only profits earned in Israel will be taxed in Israel). · Protection of property (Wealth Protection) the uncertainty of circumstances (political, economic, family, etc.). · Preparation of inheritance, which is mounted and fixed during the life of the principal, and is not dependent on the laws of the country establishing the right heritage, avoiding the threat of contesting heirs. Trust in favor of the beneficiary of the tax a non-resident of Israel in accordance Israeli tax laws, Israeli resident is not taxable for income earned abroad in Israel. A trust established in Israel in which the principal and the beneficiary are tax non-residents of Israel as well, is not subject to tax levied for the profits made outside of Israel. At the same time, no matter the identity of the trustee, it may be a resident of Israel, and yet, the taxation of the trust will be regarded as taxation of foreign residents. Moreover, according to the Israeli tax law, taxation of property management such Trust is regarded as tax beneficiary . Accordingly, if the founder and the beneficiaries of the trust are foreign residents, property management company such Trust, will also be considered as a company resident of Israel, despite the fact that it is registered in Israel. The activities and profits of such Trust beyond the borders of Israel, are not subject to reporting to the Israeli tax authorities. Taxation of income received in Israel Income Trust received in Israel, is considered as income of the beneficiary (private person), a non-resident of Israel and is subject to income tax (in the case of current income) and the tax on capital income. Income Tax ("Mas income payments") - Annual operating profit private entity, resulting in Israel is subject to tax at the following rates (valid for 2015): · For each new shekel of the first 240,000 new shekeley- 31%. · For each new shekel since NIS 240,001 and NIS to 501.960 - 34%. · For each new shekel since NIS 501.961 and 811.560 new shekeley- to 48%. · For each following new shekel- 50%. The tax on capital income (income from the alienation of property) ("Mas He PEBAX") - to review the taxation of capital income should be divided capital gains on the inflation components (capital growth as a consequence of the inflation price index) and the real part of (real growth in value of the property exceeds the increase of the price index). The inflationary component of the increase in the price of the property is not taxed. The real component of the increase in the price of property is taxed at a rate of 25%. Notwithstanding the above real capital gains on the sale of shares in companies in which the seller is a substantial shareholder or are those in the 12 months before the sale is subject to tax rate of 30%. Tax on profit from the sale of real estate ("Mas Shevach Mekarkein") - Taxes on income from the sale of real estate (real component of the profit) is also a 2014 years- 25%. 2.7. Reporting of trust: · Initial notification of the tax authorities about the fact of the establishment of the trust. · Opening the case to the tax authorities (for the establishment of a trust). · Trust "tax non-residents of Israel," which has arrived, any property in Israel is obliged to submit an annual report to the tax authorities. Trust "tax non-residents of Israel," in which there is no profit and no property in Israel is not obliged to submit an annual report to the tax authorities. Company content assets of the Trust are not required to file a separate annual report to the tax authorities in Israel. · Submission of the annual reference about the status of the content of the property to the state registrar of companies. · Submission of applications to the registrar of companies on the content of the property in the event of changes in the activity of the company, changes in the number of shares transfer of shares, change the company's bylaws, the capital increase, changes in corporate structure, changes in details, the appointment and change of directors, changing the composition of the company's management, change her name, etc. Execution of clients from Russia establishes a Trust beneficiary of which is he himself and / or destination their foreign persons (eg, family members) on the basis of an agreement with the trustee, in order that the latter managed the property (in Israel) for the benefit of the beneficiary. Trustee, in turn, establishes a legal entity in Israel (property management company Trust ), for the purpose of maintenance and asset management.