in Israel. (i) the income tax (including capital gains tax and company tax);
(ii) the security levy; (hereinafter referred to as "Israeli tax").
in Israel. (i) in respect of taxes withheld at source, for amounts paid or credited on or after the first day of January in the calendar year next following that in which such notice has been given;
(ii) in respect of other taxes, for taxable periods beginning on or after the first day of January in the calendar year next following that in which such notice has been given.
in Israel. The Customs Directorate of the Israeli Tax Authority of the Ministry of Finance or their successors.
in Israel. (i) in respect of taxes withheld at source, to amounts of income derived on or after 1 January of the year following the year the Agreement enters into force;
(ii) in respect of other taxes on income, to such taxes chargeable for any taxable year beginning on or after 1 January of the year following the year the Agreement enters into force;
in Israel. (i) the income tax and company tax (including tax on capital gains);
(ii) the tax imposed on gains from the alienation of real property according to the Real Estate Taxation Law; (hereinafter referred to as "Israeli tax").
in Israel the courts of Tel Aviv-Jaffa;
in Israel. The Central Bank; Ministry of Finance – Capital Markets, Insurance & Savings Division; The Social Security Organization; The Tax Authorities;
in Israel. (i) taxes imposed according to the Income Tax Ordinance and its adjunct laws;
(ii) tax on profit and payroll on financial institutions and insurance companies; (hereinafter referred to as "Israel tax").
in Israel. (i) the income tax (including capital gains tax and tax imposed under the Petroleum Profits Taxation Law 5771-2011);
(ii) the company tax; and
(iii) the tax on gains from the sale of land under the Real Estate Taxation Law (hereinafter referred to as “Israel tax”).”
(1) Sub-subparagraph (iii) of subparagraph (h) of paragraph (1) Article II of the Convention shall be deleted and replaced by the following: “Where by reason of the provisions of subparagraph (i) a person other than an individual is a resident of both territories, the taxation authorities of the both territories shall endeavour to determine by mutual agreement the territory of which such person shall be deemed to be a resident for the purposes of this Convention, having regard to its place of effective management, the place where it is incorporated or otherwise constituted and any other relevant factors. In the absence of such agreement, such person shall not be entitled to any relief or exemption from tax provided by this Convention except to the extent and in such manner as may be agreed upon by the taxation authorities of the Contracting Parties.”
(2) Subparagraph (k) of paragraph (1) Article II of the Convention shall be deleted and replaced by the following:
(i) For the purposes of this Convention, the term “permanent establishment” means a fixed place of business through which the business of an enterprise is wholly or partly carried on.
(ii) The term “permanent establishment” includes especially: (aa) a place of management;
