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  • Writer's pictureשוהם שאוליאן, רו״ח (עו״ד)

Wallet Company - Israeli personal service company

A conceptual image featuring a beige leather wallet with credit cards visible, standing next to a small, dark model building, with several gold coins scattered around. This illustration symbolically represents financial management of small businesses.

Optimally planning taxes can be quite complex. Take, for instance, Gideon, the CEO of 'Beautiful Tree Ltd.'. As the company progressed under his leadership, Gideon's salary increased, and accordingly, the tax rate on his salary was at the higher marginal tax brackets. To optimize his taxes, Gideon considered receiving his salary through a new company he would establish, allowing 'Beautiful Tree Ltd.' to pay management fees to this new company instead of a salary directly to him. This way, these incomes would be taxed at a lower rate (corporate tax), and Gideon could decide when to distribute the company's profits and pay the tax on dividends.


This method was popular in Israel for many years among executives and freelancers. It allowed them to control the timing of their tax obligations. While salaries were subject to immediate tax, payments received by a wallet company were only taxed as corporate tax, with the tax difference deferred until the funds were distributed as dividends or salary.

 

Starting in 2017, the Income Tax Ordinance was amended, and provisions in Section 62A regarding 'wallet companies' were enacted. According to Section 62A of the Income Tax Ordinance, the income of a wallet company is taxed as the personal income of its shareholders, according to the marginal tax rate of the shareholder.


For Gideon, working in a senior position at 'Beautiful Tree Ltd.' that means that any compensation, whether through his salary or through management fees to his company, will be subject to personal marginal tax rates according to Section 62A - effectively closing a loophole that existed in the past.


Unlike Gideon, Moshe is a talented medical consultant negotiating a contract with 'MediHeal Ltd.'. His sole income is from 'MediHeal Ltd.', and even if he chooses to receive payments through his company, according to Section 62A(2), this income will still be considered his personal income and taxed accordingly. This section significantly limits the tax planning options that were available in the past.


However, Moshe might have another option. Suppose he consults not only for 'MediHeal Ltd.' but for several companies, with 'MediHeal Ltd.' expected to account for only about 50% of his total income. Considering his expected high tax liability, Moshe wonders if he can channel his income from 'MediHeal Ltd.' through his company, thereby reducing his tax burden to corporate tax rates.


In this case, he could do so and enjoy the corporate tax rates, as Moshe does not fall under the presumption established in the provisions of Section 62A of the ordinance, given that no more than 70% of the company's income comes from a single source over a certain period.


There are additional scenarios where the section's provisions do not apply. For example, if Moshe employed 4 or more workers (who are not his family members) in his company, the provisions of the section would not apply. Similarly, if Moshe were a significant shareholder in 'MediHeal Ltd.', the situation would be different, but not only. There are various complex situations, and each case must be examined on its own.

 

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