The Israel Tax Authority has published Income Tax Circular No. 7/2017, which concerns new rules for the taxation of substantial shareholders (10% minimum ownership) on company withdrawals. The new rules provide that withdrawals of funds from a company by a substantial shareholder may be considered taxable income in the hands of the shareholder, including shareholder loans and guarantees of shareholder loans.
The time of the taxable event is the end of the year following the year in which th…