Companies and business abroad: formation, tax and disputes by country
An Israeli company entering a foreign market, or an entrepreneur setting up a company overseas, needs to know four things: which structure to set up, how much tax is paid there and in Israel, what the ongoing obligations are, and what happens in a dispute. The guides are gathered here by country.
The four questions every company asks
- 1Which structure?A subsidiary, a branch of the Israeli company or a representative office. The choice affects liability, tax and local obligations.
- 2How much tax, and how do profits come home?Local corporate tax, withholding on dividends under the tax treaty, and what is reported and paid in Israel.
- 3What are the ongoing obligations?VAT registration, local bookkeeping, annual filings, a local director or representative, and employees.
- 4What happens in a dispute?Which court or arbitration, under which law, how long it takes and how a judgment is enforced across borders.
Guides by country
For each country: company formation, corporate tax and profits to Israel, operating as an Israeli company, and commercial disputes.
Romania
Forming a Company in Romania as an Israeli: Setting Up an Operating SRL at the ONRC, Capital, CAEN Codes, Micro Regime, VAT and Bank
How an Israeli forms an operating company in Romania in 2026: SRL steps at the ONRC, 500 lei capital, registered office, UBO, CAEN codes, 1% micro regime, VAT.
10 min readAn Israeli Company Operating in Romania: Branch, Subsidiary or Representative Office, Permanent Establishment, VAT, Employees and Compliance Calendar
An Israeli company in Romania: branch vs SRL subsidiary vs representative office, PE and 16% tax, VAT and fiscal representative, staff, bank, 2026 filings.
11 min readCorporate Tax in Romania 2026 and Transferring Profits to Israel: 1% Micro, 16% Corporate Tax, Dividends, the Tax Treaty and Reporting in Israel
Romania corporate tax 2026: 1% micro up to 100,000 euros, 16% profit tax, 21% VAT, 16% dividend tax and 15% under the Israel treaty, CFC, PE and reporting.
12 min readA Commercial Dispute in Romania for an Israeli Company: Courts, Arbitration, Debt Collection, Limitation and Enforcement of Judgments
A business dispute in Romania for an Israeli company: which court, payment orders and small claims, arbitration and the New York Convention, 3-year limitation.
12 min readSetting Up an SRL in Romania to Hold Real Estate: Steps, Costs, Director, Bookkeeping and Taxation
Setting up an SRL in Romania to hold real estate: ONRC steps, minimum capital under Law 239/2025, foreign director, 1% micro vs 16% corporate tax, Israeli reporting.
10 min readCompany Structure for an Israeli Developer in Romania: SRL, Partners, Beneficial Owner and Tax
Structuring an SRL for a project in Romania: capital under Law 239/2025, shareholder loans, a local partner, deadlock, beneficial owner and tax.
6 min readBuying Property in Romania in an Individual's Name or Through a Company: Which Is Better and When
Buying property in Romania as an individual or through a company: the land limit for foreigners, a tax comparison, company costs and when a company pays off.
5 min readIsraeli Companies in Romania by the Numbers: What Central Bank and Trade Register Data Say, and How to Read Them
How much Israelis have invested in Romania: Israel's FDI stock per the National Bank of Romania, 2019-2024, Trade Register data on Israeli-owned companies and how to read it.
8 min readGreece
An Israeli Company Operating in Greece: Branch or Subsidiary, Permanent Establishment, VAT, Employing Staff and an Annual Compliance Calendar
An Israeli company in Greece: branch, subsidiary, Law 89 office or direct activity, permanent establishment, VAT representative, 920-euro minimum wage.
13 min readCorporate Tax in Greece 2026 and Transferring Profits to Israel: 22% Corporate Tax, Dividend Withholding, the Tax Treaty and the Credit in Israel
Greek corporate tax 2026: 22% rate, 24% VAT, 5% dividend withholding for Israelis, treaty rates, Israeli tax and credit, CFC and permanent establishment.
13 min readSetting Up a Company in Greece for Israelis: IKE or AE, GEMI Registration Steps, Documents from Israel and Post-Formation Obligations
Company formation in Greece for Israelis: IKE vs AE vs branch, GEMI one-stop registration, tax numbers for owners, apostilled documents, fees, reports.
12 min readCommercial Disputes in Greece: Courts, Mandatory Mediation from 2027, Arbitration, Enforcing an Israeli Judgment and Debt Collection
Commercial disputes in Greece: the courts, Law 5221/2025 timelines, the ADR Code 5344/2026, arbitration, New York Convention, judgments, payment orders.
13 min readCyprus
An Israeli Company Operating in Cyprus: Branch or Subsidiary, Permanent Establishment, VAT, Employing Staff and an Annual Compliance Calendar
How an Israeli company operates in Cyprus: branch vs subsidiary, permanent establishment risk, VAT, staff and 2026 minimum wage, work permits, bank, compliance.
11 min readCorporate Tax in Cyprus and Transferring Profits to Israel: 15% from 2026, Dividends, Withholding Tax and What Happens in Israel
Cyprus corporate tax rose to 15% in 2026: what the reform changed, dividend withholding for Israelis, Israeli dividend tax, CFC rules and director pay.
12 min readSetting Up a Company in Cyprus for Israelis: Forms of Incorporation, Registration Steps, Documents from Israel, Bank Account and Ongoing Obligations
How to set up a company in Cyprus: private limited company, official registry fees, Israeli documents with apostille, secretary, UBO register, VAT, returns.
11 min readCommercial Disputes in Cyprus: the Commercial Court, Arbitration, Enforcing an Israeli Judgment and Limitation Periods for Israeli Companies
An Israeli company in a commercial dispute in Cyprus: courts and the Commercial Court, arbitration, New York Convention, Israeli judgments, 6-year limitation.
12 min readBulgaria
An Israeli Company Operating in Bulgaria: Branch, Subsidiary or Representative Office, Permanent Establishment, VAT, Employees and an Annual Compliance Calendar
How an Israeli company operates in Bulgaria in 2026: branch vs subsidiary vs trade office, permanent establishment risk, VAT, staff, contracts, compliance.
10 min readCorporate Tax in Bulgaria 2026 and Dividends to Israel: 10% Corporate Tax, Withholding Tax, the Tax Treaty and What You Pay in Israel
Bulgarian corporate tax 2026: flat 10%, 5% dividend withholding, the Israel-Bulgaria treaty, Israeli dividend tax, foreign tax credit, CFC and PE risk.
11 min readOpening a Company in Bulgaria for Israelis in 2026: EOOD or OOD, Minimum Capital in Euros, Steps, Costs and Obligations
How an Israeli sets up a company in Bulgaria in 2026: EOOD, OOD or AD, minimum capital in euros, registration, Israeli documents, bank, VAT and reports.
10 min readBusiness Disputes in Bulgaria: Courts, Arbitration, Payment Orders, Limitation Periods and Enforcing an Israeli Judgment
Commercial disputes in Bulgaria for Israeli companies: courts, payment orders, the new Arbitration Act, New York Convention, Israeli judgments, limitation.
11 min readUnited States
Forming a US Company as an Israeli in 2026: LLC or Corporation (C-Corp), Which State, the Operating Agreement, Bank and Reporting
How to form a US company from Israel in 2026: the difference between an LLC and a corporation (C-Corp), Delaware or your operating state, what the operating agreement must cover, tax ID, bank and reporting.
10 min readAn Israeli Company Operating in the US: Subsidiary or Branch, Permanent Establishment under the Treaty, Sales Tax, Employees, E-2 Visa and Bank Account
How an Israeli company enters the US market: subsidiary vs branch, PE under the tax treaty, state registration, sales tax after Wayfair, staff, E-2 visa, bank.
12 min readUS Corporate Tax 2026 and Transferring Profits to Israel: C-Corp vs LLC, State Tax, Dividends under the Treaty and Reporting in Israel
21% federal corporate tax, state tax, branch profits tax, withholding on dividends under the Israel-US treaty (25% or 12.5%), Form 5472, BOI 2026, Israeli tax.
12 min readA Commercial Dispute in the US for an Israeli Company: State or Federal Court, Arbitration, Discovery and Enforcement of an Israeli Judgment
US commercial lawsuits for Israeli companies: state or federal court, diversity jurisdiction, ICDR arbitration, limitation, discovery, Israeli judgments.
12 min readAn LLC to Buy US Property for an Israeli Investor: Advantages, the Israeli Reporting Trap and Alternatives
Buying US property through an LLC? The advantages, the US-Israel classification gap, Income Tax Circular 5/2004, reporting duties and alternatives for Israelis.
10 min readItaly
An Israeli Company Operating in Italy: Branch, Subsidiary or Representative Office, Permanent Establishment, VAT, Employees and Reporting Calendar
How an Israeli company operates in Italy: direct sales, representative office, branch or subsidiary, PE risk, VAT representative, employees and annual filings.
11 min readCorporate Tax in Italy and Dividends to Israel: IRES and IRAP in 2026, Treaty Withholding Tax and What Happens in Israel
Italian corporate tax 2026: 24% IRES and 3.9% IRAP, treaty withholding on dividends to Israel (10% or 15%), interest, royalties and Israeli reporting.
12 min readSetting Up a Company in Italy for Israelis: S.R.L. or S.p.A., Minimum Capital, the Notaio, Documents from Israel and Post-Registration Obligations
How Israelis set up a company in Italy: S.R.L., S.R.L.S. and S.p.A. compared, minimum capital, signing before a notaio, apostille, PEC, bank and filings.
11 min readA Commercial Dispute in Italy for an Israeli Company: Courts, Mandatory Mediation, Payment Orders, Arbitration and Enforcement of Judgments
Business disputes in Italy: company courts, mandatory mediation, assisted negotiation, the decreto ingiuntivo, arbitration, limitation and Israeli judgments.
12 min readPortugal
An Israeli Company Operating in Portugal: Branch, Subsidiary or Direct Activity, Permanent Establishment, VAT, Employing Staff and Annual Filings
An Israeli company in Portugal: when a permanent representation is required (Companies Code art. 4), branch vs Lda, PE, VAT representative, 920 euro wage.
11 min readCorporate Tax in Portugal and Transferring Profits to Israel: 19% IRC in 2026, Withholding Tax on Dividends, the Tax Treaty and What Happens in Israel
Portugal corporate tax 2026: 19%, 15% for small firms, derrama, 23% VAT, 25%/28% withholding vs 5%-15% under the Israel treaty, Israeli credit, CFC and PE.
12 min readSetting Up a Company in Portugal for Israelis: Lda or SA, Registration through Empresa na Hora, Documents from Israel, Bank and Ongoing Obligations
How an Israeli sets up a company in Portugal: Lda or SA, Empresa na Hora for 360 euros, minimum capital, NIF, apostille, beneficial owner, bank, VAT, filings.
11 min readA Commercial Dispute in Portugal for an Israeli Company: Courts, Arbitration, Payment Order (injunção), Enforcement of Judgments and Limitation Periods
Business disputes in Portugal: which court, arbitration under Law 63/2011, injunção debt orders, enforcing Israeli judgments, Brussels I, Rome I and limitation.
12 min readUkraine
An Israeli Company Operating in Ukraine: Subsidiary, Representative Office or Direct Activity, Permanent Establishment, Employees and VAT under Martial Law
How an Israeli company operates in Ukraine in 2026: subsidiary vs rep office or direct activity, PE and tax registration, VAT, staff, language, currency limits.
12 min readCorporate Tax in Ukraine and Dividends to Israel 2026: 18%, the Tax Treaty, National Bank Restrictions in Wartime and Reporting in Israel
Ukraine corporate tax 18% in 2026, simplified tax, 20% VAT, withholding on dividends to Israel under the treaty (5% or 15%), EUR 1m monthly limit, Israeli tax.
12 min readSetting Up a Company in Ukraine for Israelis: Limited Liability Company (TOV), Documents from Israel, Foreign Director, Tax and Banking under Martial Law
How Israelis set up a company in Ukraine in 2026: TOV structure, no minimum capital, 24-hour registration, apostille, work permit, tax, bank.
11 min readA Commercial Dispute in Ukraine for an Israeli Company: Commercial Courts, Arbitration, Limitation and Enforcement of Judgments in Wartime
Handling a commercial dispute in Ukraine in 2026: commercial courts, 1.5% court fee, ICAC arbitration, New York Convention, 3-year limitation, Israeli rulings.
12 min readGeneral guides
Setting Up a Company Abroad for Israelis in 2026: Comparing 8 Countries on Corporate Tax, Dividends to Israel and Disputes
Company formation abroad for Israelis compared in 8 countries: company form, minimum capital, 2026 corporate tax, dividend withholding, treaties, disputes.
8 min readTax for an Israeli Investor in a Foreign Project Company: Dividends, Capital Gains, Controlled Foreign Company and Tax Treaties
How Israel taxes an investor in a foreign property project company: 25% or 30% dividends, capital gains on shares, surtax, foreign tax credit, CFC and treaties.
9 min readA Dispute with a Developer Abroad: Arbitration or Court, and Where, According to the Jurisdiction Clause in the Contract
Where a dispute with a developer abroad is heard: jurisdiction, governing law, arbitration, enforcing foreign judgments and awards, and what to negotiate first.
9 min readEnforcing an Israeli Judgment Abroad and a Foreign Judgment in Israel: Recognition in the EU, the New York Convention and the 2019 Hague Convention
How to enforce an Israeli judgment in Europe and a foreign judgment in Israel: the Foreign Judgments Enforcement Law, EU recognition, the New York Convention and Hague 2019.
12 min readGoverning Law, Jurisdiction and Arbitration Clauses in an International Contract: Rome I, Brussels I Recast, ICC, VIAC and Arbitration in Bucharest
What to decide in a governing law, jurisdiction and arbitration clause with a European party: Rome I, Article 25 of Brussels I Recast, ICC, VIAC and CCIR, language and a checklist.
11 min readA Joint Venture with a Local Partner Abroad: Contractual JV or Joint Company, Shareholders' Agreement, Deadlock, Exit and Vetting the Partner
How to structure a joint venture with a local partner abroad: contractual JV or joint company, shareholders' agreement, deadlock, drag and tag, in-kind contributions, UBO checks.
10 min readAcquiring a Company Abroad: Share Deal or Asset Deal, Due Diligence, the Purchase Agreement, Foreign Investment Screening and Reporting in Israel
Buying a local company abroad: share vs asset deal, due diligence checklist, warranties, indemnities and escrow, EU and Romanian foreign investment screening, Israeli reporting.
11 min readControlled Foreign Company and Foreign Professional Company: When a Foreign Company's Profits Are Taxed in Israel as a Deemed Dividend
Controlled foreign company (section 75B) and foreign professional company (section 75B1): conditions, deemed dividend, the control and management test, warning signs and reporting.
10 min readA Business Bank Account Abroad for an Israeli Company or an Israeli-Owned Foreign Company: Documents, Remote Opening, CRS and Reporting in Israel
How to open a business bank account abroad for an Israeli company or an Israeli-owned foreign company: KYC and controlling persons, remote opening, digital institutions, CRS.
9 min readInvoicing a Client Abroad: Zero-Rated VAT in Israel, Reverse Charge in the European Union and OSS for Digital Services
Invoicing a client abroad: when a service to a non-resident is zero-rated (section 30(a)(5)), reverse charge for EU business clients, OSS for digital services to consumers, foreign VAT.
9 min readPermanent Establishment and a Remote Employee Abroad: When an Israeli Company Is Taxable in the Employee's Country, and What About Payroll and Social Security
An employee working from home abroad may create a permanent establishment for an Israeli company. Fixed place, dependent agent, building site, OECD 2025 home office update, payroll.
10 min readClosing a Company Abroad: Voluntary Liquidation vs Strike-Off, Tax Clearance, Closing the Bank Account and the Tax Consequences in Israel
How to close a company abroad: voluntary liquidation vs strike-off in Romania, Bulgaria, Greece, Cyprus and Delaware, tax clearance, final returns, bank account and Israeli tax.
9 min readData Protection for an Israeli Company Selling to Europe: When the GDPR Applies, an EU Representative, the Adequacy Decision and Amendment 13
When the GDPR applies to an Israeli company without an EU branch, when an EU representative is needed under Article 27, Israel's adequacy decision, Amendment 13 and a checklist.
9 min readDoing Business with an Israeli Company or Investor: A Practical Guide for the Foreign Partner - Checking the Company, Signing Authority, Contracts, Tax and Payments
A guide for a foreign partner working with an Israeli company or investor: checking an Israeli company at the Registrar, signing authority, contract law, tax treaties, withholding, payments.
9 min readHow we support companies and businesses
- 1
Company formation and partnership structures
Choosing the structure, articles and shareholders' agreement, and registering the company in the target country.
- 2
Representing the company abroad
Before authorities, banks, partners and suppliers, together with local lawyers and accountants.
- 3
Commercial contracts
Drafting and reviewing contracts, including governing-law, jurisdiction and arbitration clauses.
- 4
Disputes and litigation
Managing a dispute with a partner, customer or supplier abroad, and enforcing judgments.
Frequently asked questions about doing business abroad
Can an Israeli set up a company abroad without travelling there?
In many of the countries covered here a company can be formed through an attorney-in-fact or an online filing, with Israeli documents translated and apostilled. Opening the bank account is the stage that sometimes requires attending in person. Details for each country are in its company-formation guide.
What is the difference between a subsidiary and a branch of an Israeli company?
A subsidiary is a separate legal entity whose liability is limited to its own assets. A branch is part of the Israeli company itself, so the Israeli company is directly liable for its debts. The distinction also affects tax in the target country and in Israel.
How are profits moved from a company abroad to Israel?
Usually as a dividend. The country where the company operates withholds tax under its domestic law or under its tax treaty with Israel, if there is one, and in Israel the dividend is taxable with a credit for the foreign tax under the rules. The structure is best coordinated in advance with an Israeli accountant.
What is a permanent establishment, and why does it matter for an Israeli company?
A permanent establishment is a fixed business presence in another country, such as an office or an agent who concludes contracts on the company's behalf. Where there is one, the other country may tax the profits attributable to it. That is why the structure should be checked before operations begin.
Where will a dispute with a partner or customer abroad be heard?
Mainly according to the jurisdiction, governing-law and arbitration clauses in the contract, within the limits of local law. The key question is where the judgment can be enforced. An arbitral award is enforceable in most countries under the New York Convention, while a court judgment needs recognition proceedings in the other country.
Does a company abroad need a local director?
It depends on the country and the structure. Some countries do not require a resident director, while others require a local representative or registered address. Even where it is not required, managing the company from Israel in practice may affect where it is liable to tax.
Does Adv. Leibovitch also advise companies outside real estate?
Yes. The firm advises Israeli companies and business owners on company formation, representing the company abroad, commercial contracts and disputes, working with local lawyers and accountants in each country.
Starting operations abroad, or facing a dispute?
In an introductory call we will understand the goal, review the structure and set out the next steps.
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