Epstein File EFTA01380310: Israel and Submission (DS10)

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Epstein File EFTA01380310: Israel and Submission (DS10)

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This document discusses an Israel Withholding Tax Ruling obtained by Mobileye and a Purchaser to exempt non-Israeli resident shareholders from Israeli withholding tax obligations. The ruling addresses tax treatment of payments to non-Israeli brokers and establishes conditions under the Israeli tax ordinance. The document references submission requirements and conditions for the tax exemption.

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Israel submission

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Excerpt 1

Mobileye and Purchaser obtained the **Israel** Withholding Tax Ruling in order to exempt shareholders who are not Israeli residents, as determined under the

Excerpt 2

tax subject to certain conditions stated in the Ordinance, and provided such gains do not derive from a permanent establishment of such shareholder in **Israel**

Excerpt 3

The **Israel** Withholding Tax Ruling provides, among other things, that (1) payments made to non-Israeli brokers with respect to tendering Mobileye shareholders