israeli-corporate-tax-strategy

Compares salary, dividend, shareholder loan, and management fee extraction for Israeli controlling shareholders.

Updated Jan 9, 2026
One-click install
npx skills add https://github.com/amitpo23/cfo --skill israeli-corporate-tax-strategy-amitpo23
Or copy as Structured Prompt for Agent
Please help me install this Agent Skill.
Skill: israeli-corporate-tax-strategy
Source: https://github.com/amitpo23/cfo/tree/main/.claude/skills/israeli-corporate-tax-strategy
Command: npx skills add https://github.com/amitpo23/cfo --skill israeli-corporate-tax-strategy-amitpo23

SYSTEM DOCUMENTATION & REQUIREMENTS

💡 This Skill includes scripts (resource) and references (resource) components.

What problem does it solve? Israeli company owners (baalei shlita) must choose between salary, dividends, shareholder loans, and management fees when extracting profits, and each method carries different tax rates, Bituach Leumi implications, and compliance risks. This Skill models the total tax burden across all four methods using verified 2026 rates, preventing costly mistakes like using the wrong dividend rate or missing Section 3(tet1) reclassification deadlines. ## Core Features & Use Cases - Side-by-Side Extraction Comparison: Calculates effective tax rates for salary (10%-50% brackets plus NI), dividends (46.1% combined for controlling shareholders), shareholder loans (6.53% Section 3(tet) deemed interest), and management fees (with 18% VAT), then recommends the optimal mix by extraction size. - Compliance Gate Checks: Applies the Section 62A personal-services look-through test, tracks Section 3(tet1) end-of-following-year reclassification deadlines, and flags trapped-profits 2% surtax exposure under Amendment 277. - Bundled Calculator and References: Ships a Python comparison script plus reference files covering 2026 tax brackets, NI ceilings, credit points, and deemed-interest rules, with an evidence.json tracing every figure to official sources. - Use Case: A shareholder needs 500,000 NIS to pay a tax assessment. The Skill checks Section 62A applicability, compares a short-term loan bridge against an immediate dividend, and outputs the net-after-tax result of each path. ## Quick Start Ask the assistant to compare salary versus dividend versus a shareholder loan for extracting a specific amount from your Israeli company, providing your ownership percentage and current salary.

Frequently Asked Questions about israeli-corporate-tax-strategy

High-intent search queries and answers about installing and using this skill.

FAQPage Schema
How do I compare salary vs dividend for an Israeli company owner?

Compare the combined effective rates: salary avoids the 23% corporate tax but triggers progressive income tax (10%-50%) plus Bituach Leumi, while dividends cost 23% corporate tax plus 30% withholding for controlling shareholders, totaling 46.1%. The Skill's Python calculator runs both scenarios with your actual figures.

What is the Section 3(tet) deemed interest rate for shareholder loans in 2026?

The Section 3(tet) deemed interest rate for 2026 is 6.53% for non-CPI-linked loans, and 4.9% under Section 3(yod) for CPI-linked loans between related parties. The difference between actual interest charged and this rate is taxed as income to the borrowing shareholder.

When is a shareholder loan automatically reclassified as a dividend in Israel?

Under Section 3(tet1), a loan from a closely-held company to a controlling shareholder is automatically deemed withdrawn if not repaid by the end of the tax year following the year of withdrawal. Balances under 100,000 NIS are exempt, and personal use of company assets also counts.

Does this skill handle VAT reporting or payroll processing?

No. The skill explicitly excludes VAT reporting, payroll processing, annual tax return filing, and crypto tax, directing those to dedicated skills. It focuses solely on profit extraction strategy for controlling shareholders.

What is the dividend tax rate for a controlling shareholder in Israel?

Controlling shareholders holding 10% or more pay 30% dividend withholding tax, not the 25% rate for minority holders. Combined with 23% corporate tax on the underlying profit, the effective total burden is 46.1%, rising toward 51.95% above the 721,560 NIS surtax threshold.

When does Section 62A make salary vs dividend optimization irrelevant?

Section 62A applies when a closely-held company's revenue comes mainly from one shareholder's personal services to a single substantial client, with profits above a 25% margin. In that case profits are attributed to the shareholder at marginal rates regardless of the extraction method chosen.