Every aliyah briefing repeats that a new Israeli resident is exempt from tax for ten years. Section 14(a) of the Income Tax Ordinance says something narrower: exempt on income produced or accrued outside Israel, or originating in assets outside Israel 1. What decides is where the asset sits, not where the account sits. Section 89(b)(3) settles the question for you: it sources a capital gain to Israel where the asset sold is located in Israel and, as a separate limb, where the asset is "a share or a right to a share in a body of persons resident in Israel" 1. Israeli shares held at an Israeli institution are Israeli-source on day one, and they are taxed in full from your first day of residency, usually while you are still telling people you are exempt for a decade.
*This is general information, not tax, legal, or financial advice. Cross-border (US/UK) and Israeli tax interact in complex ways, and inflation-adjusted basis is one of the places they interact worst. Consult a qualified cross-border professional before acting.*
This page is about the charge, not the channel. Choosing where the account lives is covered in investing through an Israeli bank and brokerage options.
Does the ten-year exemption cover an Israeli investment account?
Not the Israeli securities inside it. Section 14(a) gives a first-time Israeli resident and a veteran returning resident ten years of exemption, but only on income produced or accrued outside Israel or originating in assets outside Israel, and section 97(b)(1) mirrors it for capital gains on an asset the individual "had outside Israel" 1. Both tests ask about the asset rather than the account, and section 89(b)(3) sources a gain on a share in an Israeli-resident company to Israel, so that gain is not income produced outside Israel 1. The account therefore carries no exemption for its Israeli holdings from day one, while a foreign security you happen to custody here is a different matter, dealt with further down.
That is the specific confusion worth naming, because it survives contact with otherwise good advice. The ten-year window is real and generous, and it covers the brokerage account you left behind in New York or Manchester. It does not attach itself to an Israeli share because the share is bought with money you brought over. If you are still mapping the window itself, the ten-year exemption guide covers what it does reach, and the 2026 reform page covers how the reporting rules changed and which arrival cohorts they changed for. One adjacent sentence and no more: electing the acclimation year under section 14(b) delays your residency start by twelve months but counts that year into the ten, on notice to the Director within 90 days of arrival 1, and the acclimation year page has the mechanics.
What number does Israel actually tax inside the account?
Israel taxes the real capital gain, meaning your gain after the inflation component has been lifted out of it. Section 88 builds that number in four steps 1:
- Adjusted original cost. Your cost multiplied by the *madad* (מדד, the consumer price index) for the sale day and divided by the madad for the purchase day, each being the index last published before that day. Securities carry no depreciation and no improvement expenditure, so it collapses to cost x (index at sale / index at purchase).
- Capital gain (*revach hon*). Sale proceeds minus the plain original cost.
- Inflationary amount. The part of the capital gain equal to the excess of the adjusted original cost over the plain original cost. Because the definition carves it out of the gain, it can never be larger than the gain itself.
- Real capital gain. Capital gain minus the inflationary amount. This is the figure the rate is applied to.
The madad is the consumer price index published by Israel's Central Bureau of Statistics, which states on its own subject page that the index "is published on the 15th of every month" 3. If you arrived from a country that taxes the number your statement shows, this is the first structural difference to absorb: the taxable gain here is smaller than the gain you can see, and neither you nor your institution gets to choose that.
Then comes the line that makes the relief nearly total. Section 88 defines the *taxable* inflationary amount as only the inflation that would have accrued had the asset been sold on 31 December 1993 1. Anything bought on or after 1 January 1994 therefore has a taxable inflationary amount of nil, and the whole inflation slice escapes. Anything bought after you landed is post-1994 by definition. Section 91(c) charges a flat 10% on whatever taxable inflationary amount does exist, which on a post-1994 holding is nothing at all 1.
There is also a door in that definition that only you can walk through. Section 88's index definition adds that a person who, while being a foreign resident, lawfully acquired an asset in foreign currency may request that the exchange rate at which the asset was acquired be treated as the index 1. The eligibility condition is having been a foreign resident at purchase, which a lifelong Israeli can never satisfy. Two cautions attach. It is a request, not an automatic entitlement. And a separate limb of the same definition already makes the exchange rate mandatory, not elective, for an individual's security denominated in or linked to foreign currency, which is the case shekel-measured gains on foreign assets owns end to end. Wherever an exchange rate does the work, note that the Bank of Israel publishes a representative shekel rate on each foreign-currency business day and says in its own words that the rate "is an indicator of the exchange rate in use but has no obligatory status under law" 4.
Which rate applies to what you sold?
You do not pick a row; the instrument you hold picks it for you. Read the fourth column, because the Ordinance does not phrase these rates the same way: 91(b)(1), 91(b)(2), 91(b)(3)(a) and 125C(b) are ceilings, worded "at a rate not exceeding", while 91(c) and 125C(c)(1) are flat charges 1.
| What you sold inside the account | What Israel measures | Rate | Section and form |
|---|---|---|---|
| Shares, index-linked bonds, units in an exempt trust fund | Real capital gain, inflation removed | 25% | 91(b)(1), ceiling |
| The same, where you are a substantial shareholder (10% or more of any class of means of control, at sale or at any point in the preceding 12 months) | Real capital gain | 30% | 91(b)(2), 88, ceiling |
| A bond, commercial paper, a loan or a state loan that is not index-linked | The whole gain, treated as real gain | 15%, or 20% for a substantial shareholder | 91(b)(3)(a), ceiling |
| The pre-1994 inflation slice, if you bought before 1 January 1994 | Taxable inflationary amount | 10% | 91(c), flat |
| Interest, general rule | The interest | 25% | 125C(b), ceiling |
| Interest on an asset that is not index-linked | The interest | 15% | 125C(c)(1), flat |
Two qualifications sit under that table. Units are on the top row only where the fund is an exempt trust fund (*keren ne'emanut petura*), the shape in which the investor rather than the fund carries the charge; section 97(a)(7) exempts an individual outright on a gain from selling or redeeming a unit in a *taxable* trust fund, because that fund was taxed at its own level 1. And the transitional rates in section 91(b1), which split a gain across the 2003 and 2012 boundary dates for assets bought before them, are switched off by section 91(b1)(1b) for securities listed on the exchange before the 2012 date and for units in an exempt trust fund 1, which is why an ordinary listed portfolio reads straight off the table above.
The trade running through the table: on index-linked instruments Israel charges more (25%) on less (the real amount), and on unlinked instruments it charges less (15%) on the whole nominal amount. Interest goes to full section 121 rates instead in the cases section 125C(d) lists, among them interest that is business income, interest on an asset for which you claimed a deduction for interest and linkage, interest from a body in which you are a substantial shareholder, and interest from a payer you work for or have other special relations with 1. Arriving with a home-country mental model in which one capital-gains rate covers everything, or in which the rate turns on how long you held, is the fastest way to misread this table: none of the rates in it turns on a holding period 1. Note also that a unit in an exempt trust fund sits on the cleanest row here, and if you carry a US passport that same row is the worst outcome on the page. Hold that thought.
Is 25% always the number, or is it a ceiling?
It is a ceiling. Section 91(b)(1) charges an individual's real capital gain "as stated in section 121, at a rate not exceeding 25%", treating the gain as the top rung of taxable income 1. Section 121(a)'s ladder for an individual opens at 31%, so for most people the ceiling binds and the gain is effectively flat. Section 121(b)(1) opens a reduced ladder of 10%, 14%, 20% and 31%, but only for income from personal exertion and for the taxable income of an individual aged 60 or over 1. A capital gain is not personal-exertion income, a term section 1 builds around employment, pension and retirement receipts 1. Age is the only door.
That matters more here than it would in any Hebrew-audience explainer, because retirees are a large aliyah cohort and many arrive with little or no Israeli employment income. An oleh of 62 living on a foreign pension, selling shares from an Israeli account, can land on a rung below 25%. Withholding under section 164 happens at the rates prescribed by regulation rather than by reference to your personal ladder 1, so any difference comes back only by filing an annual return. No bracket amounts appear on this page on purpose: section 120B re-indexes every income ceiling on 1 January by the previous year's rise in the index, so a number printed today is wrong next January 1. Israel's tax year is a calendar year by definition 1, and your first one usually covers only the months since you arrived, which moves you on that ladder; see your first Israeli tax year.
Why does withholding at an Israeli institution leave you with nothing to file?
Because the Ordinance switches the reporting duty off, rather than waiving it as a courtesy. Section 164 obliges whoever pays, or is responsible for paying, "consideration as defined in section 88", interest or a dividend to withhold at the time of payment, in the manner and at the rates prescribed by regulation 1. Section 91(d)(1) would otherwise demand a report to the assessing officer within 30 days of any asset sale, on the Director's form, plus an advance payment of the tax due 1. Section 91(d)(2C)(a) then provides that subsection (d) does not apply to a gain on the sale of an exchange-listed security or a fund unit "if at the time of sale tax was withheld from the capital gain under section 164" 1.
Read those words again: withheld from the capital gain, not from gross proceeds. Your Israeli institution is running the whole of the section 88 computation, index adjustment included, before it takes anything. The instinct most newcomers arrive with, that an investment year ends with a return, is the wrong instinct here: a resident whose only investment income is this account, and who has no separate duty to file, has nothing left to report on the sale. It is also the sharpest contrast with the account you may still hold abroad, where nobody withholds, where section 91(d)(2C)(b) puts a seller who is required to file under section 131 on a 31 July and 31 January cycle covering the previous six months, with an advance paid on each, and where the duty is entirely yours 1. The foreign-brokerage self-reporting page owns that half of the picture.
What does that withholding not settle?
Three things, and each is likelier to bite an oleh than a lifelong Israeli.
It is per-payer. Section 164 puts the duty on each payer separately, at the moment of payment 1. Offsetting lives somewhere else entirely: section 92 sets a capital loss first against your real capital gain, lets a loss on a security also run against interest and dividends on that and on other securities, and makes carrying an unused loss into later years conditional on having filed a return for the year of the loss 1. Olim characteristically run two accounts at once, one Israeli and one left behind, which is exactly the shape that produces an offset the withholding machinery cannot see.
The high-income surtax is outside the advance machinery. Section 121B(b) states that section 91(d)'s advance provisions do not apply to income chargeable to the additional tax 1. This page prints no surtax rate or threshold; confirm the current figures with the Israel Tax Authority. The mechanism is worth one line because it shows the real-gain principle running all the way up: section 121B(e) defines taxable income for that section excluding "an inflationary amount as defined in section 88" 1.
Your other government is not a party to any of it. The withholding settles Israel. It settles nothing with the IRS, which taxes a US citizen on worldwide income from all sources wherever they live 13, and it proves nothing to HMRC, which decides your UK exposure by residence 10. That is what the next three sections are for.
Worked example: what does a NIS 150,000 gain actually cost?
Say you have been resident three years, you are under 60, and you hold shekel-denominated, exchange-listed shares in an Israeli investment account. You bought for NIS 250,000 when the index stood at 120.0 and sold for NIS 400,000 when it stood at 138.0. Those index points are illustrative, not real CPI readings.
- Adjusted original cost: 250,000 x 138.0 / 120.0 = NIS 287,500
- Capital gain: 400,000 - 250,000 = NIS 150,000
- Inflationary amount: 287,500 - 250,000 = NIS 37,500
- Taxable inflationary amount: nil, because the purchase was after 1 January 1994
- Real capital gain: 150,000 - 37,500 = NIS 112,500
- Israeli tax at the section 91(b)(1) ceiling: 25% x 112,500 = NIS 28,125
- Effective rate on the headline NIS 150,000: 28,125 / 150,000 = 18.75%
- The 30-day report and advance: switched off by section 91(d)(2C)(a), once tax was withheld from the gain
Now push the same nominal gain through the unlinked-debt row instead, where the whole gain counts as real: 15% x 150,000 = NIS 22,500, an effective 15%. The lower headline rate really is the cheaper bill here. The break-even is arithmetic you can run yourself: 25% of the real gain equals 15% of the nominal gain exactly when the inflationary amount is 40% of the nominal gain, because 0.25 x 0.6 = 0.15. Above 40%, the index-linked treatment wins. In this example inflation was 37,500 of 150,000, or 25% of the gain, below that line, so the unlinked figure is the smaller one. A long holding through a high-inflation stretch flips it.
The same trade, three ways:
| Who is selling | What changes |
|---|---|
| A lifelong Israeli under 60 | Nothing further. The tax is settled at source and no 30-day report or advance follows. |
| An oleh aged 62 with little Israeli income | The reduced section 121(b)(1) ladder is open, so the 25% ceiling may not bind. Withholding still runs at the prescribed rate, and the difference returns only through an annual return. |
| A US-citizen oleh | The IRS computes its own gain in dollars from a cost basis that carries no inflation adjustment, so nothing corresponding to the NIS 37,500 slice is ever taken out. The Form 1116 credit is capped both by the Israeli tax actually paid and by the limitations US law provides. The 3.8% net investment income tax can apply on top, with no foreign tax credit against it. |
Israeli treatment: which oleh rules reach this account, and which stop at the border?
One exemption you may have relied on for years ends the morning you land, and one you have probably never heard of may follow you across.
The exemption that stops at the border. Section 97(b2) exempts a *foreign resident* from Israeli tax on capital gains from securities traded on the exchange in Israel, provided the gain is not attributable to a permanent establishment in Israel 1. Diaspora investors hold Israeli listed securities for exactly that reason. The exemption is a property of your residence status, not of the shares, so it is worth nothing the morning after aliyah. The same holding that produced untaxed gains for a decade becomes a 25% real-gain charge because you changed address. No lifelong Israeli has ever held that exemption and none can lose it. It carries its own carve-outs, including a share in a real-estate investment fund and Israeli state debt listed on the exchange with a redemption date no more than 13 full months from issue 1. The banking half of the same event, telling your institution you are now a resident, sits on foreign-resident account becomes resident.
The rescue that may follow you across. Section 97(b3)(3) applies the foreign-resident exemption, with the necessary changes, to an individual who became a first-time Israeli resident or a veteran returning resident, provided they were a foreign resident when they acquired the security, and treats the gain as if the security had been an asset held outside Israel before aliyah 1. That pulls a pre-aliyah holding in an Israeli company into the ten-year window of section 97(b). But it rides on subsection (b3), and among the conditions in its paragraph (1) is (f), that the security "was not traded on the exchange in Israel at the time of sale" 1. So a pre-aliyah stake in an unlisted Israeli company can carry foreign-asset treatment across the border, while pre-aliyah listed shares in an Israeli company cannot. Two Israeli holdings bought on the same day, two different answers, decided by whether one of them is quoted. A security that was unlisted when you bought it and listed by the time you sell is not a case this page resolves for you; that needs professional advice on the actual facts.
Two more, briefly. If your Israeli account holds *foreign* securities whose gain is exempt under section 14(a) or 97(b)(1), the statutory exemption and the statutory withholding duty point in opposite directions, and your institution will withhold unless the assessing officer says otherwise. Ask the Israel Tax Authority what approval it wants before you sell, not after. And do not treat "returning resident" and "veteran returning resident" as one thing: the ten-year exemption belongs to the veteran category, an individual who again became an Israeli resident after being a foreign resident for at least ten consecutive years, while a plain returning resident is one who was a foreign resident for at least six consecutive years and gets a narrower five-year benefit on a defined list of income types 1. Israeli-issuer debt bought in the diaspora is a different object with the same structural lesson; see Israel Bonds. If a foreign asset is sold after the window closes, Israel splits the real gain by a purchase-to-sale time ratio; see year eleven.
If you hold a US passport or a green card, what does Israel's relief cost you?
Part of your foreign tax credit, which is the least intuitive sentence on this page. Nothing about aliyah ends your US filing: the IRS states that for a US citizen or resident alien the rules are generally the same whether you are in the United States or abroad, and that you are subject to tax on worldwide income from all sources 13. On top of that, the US computation gives basis no inflation adjustment. IRS Topic 409 measures the gain as the difference between your adjusted basis and the amount realised, and says that "generally, an asset's basis is its cost to the owner" 7. Long-term gains run through a 0%, 15% and 20% structure whose thresholds the IRS page still stated on a "for taxable years beginning in 2025" basis when checked on 25 August 2026, and net short-term gains are taxed as ordinary income 7.
Put the two systems side by side on the worked example. Israel taxed NIS 112,500 rather than NIS 150,000, because it lifted the inflation slice out first. The United States runs its own computation in dollars with nothing lifted out. The Israeli tax you actually paid is one ceiling on your credit, and the limitation United States law provides for the taxable year is the other, which Article 26(1) of the convention states in those terms 2. The IRS allows a credit for foreign taxes imposed on you where you are subject to US tax on the same income, claimed by individuals on Form 1116 8. A smaller Israeli base means a smaller Israeli tax, which means a smaller credit against a US bill that was never reduced in the same way. Israel's inflation relief is part of the reason your US liability survives.
On top of that sits the net investment income tax, imposed by section 1411 at 3.8% on certain net investment income above statutory thresholds and in force since 1 January 2013 6. Gains from selling stocks, bonds and mutual funds are named on the IRS list of net investment income 6. The IRS is explicit that foreign income tax credits under sections 27(a) and 901(a) "are allowed as credits only against the tax imposed by chapter 1 of the Code, and therefore may not be used to reduce your NIIT liability", while adding that foreign income taxes taken as a deduction instead may reduce net investment income 6. As a credit, every shekel of Israeli tax buys nothing against the 3.8%.
One more, and it is why the cleanest row of the rate table is your worst option. A shekel fund unit inside an Israeli account is a non-US pooled fund, which means the passive foreign investment company regime. A US person who is a direct or indirect PFIC shareholder files Form 8621 on certain distributions, on recognising a gain on a disposition of PFIC stock, when reporting a qualified electing fund or section 1296 mark-to-market election, when making an election reportable in Part II of the form, or when required to file an annual report under section 1298(f) 5. Israel's answer for that unit is mild either way: a 25% ceiling and no 30-day report for a unit in an exempt trust fund, and an outright exemption under section 97(a)(7) for a unit in a taxable one 1. The US answer arrives long before Israel's arithmetic matters. Start at the PFIC problem; if you already hold one, cleaning up a PFIC and the US-domiciled account route.
If you came from the UK, does Britain still tax this account?
No, once you are genuinely UK non-resident. GOV.UK states it plainly: "Non-residents only pay tax on their UK income, they do not pay UK tax on their foreign income" 10. Residence turns on the Statutory Residence Test: you are UK resident only if you meet an automatic UK test or the sufficient ties test and meet no automatic overseas test. The automatic UK tests include spending 183 days or more in the UK in the tax year; the automatic overseas tests include fewer than 16 UK days, or fewer than 46 if you were not UK resident in the three previous tax years 10. The UK tax year runs 6 April to 5 April 10, which will not line up with Israel's calendar year in your year of arrival.
Now the part that should feel oddly familiar, and it is the reason this section could never appear in a Hebrew-audience article. Britain ran Israel's exact mechanism. Sections 86 to 89 and Schedule 13 of the Finance Act 1982 introduced the indexation allowance, so that "for assets acquired after March 1982, the chargeable gain becomes approximately the 'real' gain, that is, the gain after making an allowance for inflation" 9. FA98 froze it at April 1998 for capital gains tax purposes, and FA08 introduced TCGA92/S52A so that indexation applies only for corporation tax, which HMRC's own manual calls "the withdrawal of indexation allowance with effect from 6 April 2008" 9. If you bought UK shares before 1998 you held an indexed basis, watched Westminster freeze it, then watched it go. In Israel you have met it again under a Hebrew name.
For comparison, all as GOV.UK states it: higher and additional rate taxpayers pay 24% on gains from 6 April 2026; basic rate taxpayers pay 18% on gains made from 6 April 2026 within the basic Income Tax band and 24% above it; the Capital Gains tax-free allowance is £3,000 for the 2026 to 2027 tax year, and the basic rate band used in the same worked examples is £37,700 for the 2026 to 2027 tax year 11. Note the shape of the difference rather than the rates. Britain puts its relief in an annual exempt amount and then taxes the nominal gain 11. Israel puts its relief in the base: section 88 lifts the inflation slice out, and section 91 charges the real gain that remains 1.
If you came from Canada or South Africa, what changes?
Less than a US oleh faces, on this account, because neither charge follows the passport. The Canada Revenue Agency states that "as a non-resident of Canada, you pay tax on income you receive from sources in Canada", and that you are a non-resident where you routinely live in another country, have no significant residential ties in Canada, and either live outside Canada throughout the tax year or stay fewer than 183 days 14. The South African Revenue Service states that from 1 March 2001 South Africa moved from a source-based to a residence-based system for individuals, so that "tax residents would be subject to tax on worldwide income (excluding certain exemptions or exclusions) and non-residents would be subject to tax on income from a source within South Africa" 15. Once your tax residence in either country genuinely ends, the ongoing Israeli charge described above is the only one running on this account. What each country does have is a charge on the way out, triggered when that residence ends, and that is a separate event. Canadian olim should start with the departure tax and deemed disposition and the Canada treaty; South African olim with the South Africa treaty.
What does the US-Israel treaty settle, and what does it leave behind?
It settles which country charges first and guarantees a credit mechanism, and it does not equalise the two computations. Read the operative text rather than the original: the convention was signed on 20 November 1975 and then amended by protocols of 30 May 1980 and 26 January 1993, and those protocols rewrote three of the five capital-gains exceptions and the saving-clause list 2.
Article 15 (Capital Gains) exempts a resident of one state from tax by the other on gains from the sale, exchange or other disposition of capital assets, subject to five exceptions. As amended they are: a gain subject to tax by the other state under Article 7 (Income from Real Property); a gain on property described in Article 14(2)(c) (Royalties); a gain treated under Article 8(6) (Business Profits) as industrial or commercial profits attributable to a permanent establishment in the other state; presence in the other state for 183 days or more in the taxable year; and a gain by a resident of either state on stock in a corporation of the other state where that seller owned, directly or indirectly, stock possessing 10 percent or more of the voting power at any time in the 12 months before the sale 2. That last one deserves a second read. The 1975 text reached only a US resident selling into an Israeli corporation and set the bar above 50 percent of voting power plus an asset-location test; the 1993 protocol made it symmetric and dropped the bar to 10 percent 2. For an Israeli-resident individual selling ordinary listed Israeli securities, none of the five bites and the primary charge is Israel's. For an oleh who carried a 10 percent stake in a US corporation across, exception (e) does bite, and Article 4(6) as amended deems that gain to arise in the other state rather than in Israel 2, which is the opposite of what a US-citizen oleh's foreign tax credit needs.
Article 6 (General Rules of Taxation) then removes most of the comfort for anyone holding a US passport. Article 6(3) provides that "notwithstanding any provisions of this Convention except paragraph (4), a Contracting State may tax its residents ... and its citizens as if this Convention had not come into effect", and Article 6(4)(a), as the two protocols left it, preserves a short list from that override: Articles 10 (Grants), 15-A (Charitable Contributions), paragraphs (2) and (3) of Article 20 (Private Pensions and Annuities), 21 (Social Security Payments), 26 (Relief from Double Taxation), 27 (Nondiscrimination) and 28 (Mutual Agreement Procedure) 2. Both halves belong in one breath: the treaty does not exempt a US citizen from US tax, it makes sure the credit survives the saving clause. Check the article number before you rely on any summary of this treaty, including this one, because its numbering is not the OECD model's: dividends are Article 12 here and Article 10 is Grants 2.
The relief article is Article 26, and the paragraph written for an oleh who holds a US passport is paragraph (2), not the general paragraph (1). Article 26(1) obliges the United States to allow a citizen or resident a credit against US tax for "the appropriate amount of taxes paid or accrued to Israel", capped by the limitations US law provides for the taxable year and sourced under Article 4 (Source of Income) 2. Article 26(2), as replaced by the 1993 protocol, covers the case of a United States citizen who is a resident of Israel: for items of income that are exempt from US tax, or taxed at a reduced US rate, when derived by an Israeli resident who is not a US citizen, Israel credits only the tax the United States may impose under the convention other than tax imposed solely by reason of citizenship; the United States then credits the Israeli income tax paid after that credit; and for the exclusive purpose of relieving double taxation in the United States, those items are deemed to arise in Israel to the extent necessary 2. Article 26(3) runs the other direction: Israel allows an Israeli resident a credit against Israeli tax for income taxes paid to the United States, capped by the proportion that the resident's net US-source income bears to total net income 2.
So the honest reading is uncomfortable and correct. Israel taxes a base with inflation stripped out. The United States taxes a base with nothing stripped out. The credit refunds only tax actually paid on the doubly-taxed slice, and the 3.8% net investment income tax sits outside the credit entirely 6. A US-citizen oleh can pay Israel in full, claim everything the treaty allows, and still owe the IRS. That is a treaty working as written, not a mistake. For treaty mechanics beyond a securities gain, see tax treaties and double tax relief and the foreign tax credit.
How solid are the sources behind this page?
Solid on structure, and dated on numbers, and the difference matters when you act on it. The Israeli provisions above were read in the Israel Tax Authority's own consolidated Hebrew text of the Income Tax Ordinance, a file generated in January 2023 1, against the Ordinance's Knesset law record 12. Every Israeli provision quoted here is translated from that Hebrew, and Hebrew subsection letters are rendered by alphabetical position, so ג appears as (c) and ה as (e). Section numbers and structure are long-standing, but rates and thresholds move, and this page therefore prints no Israeli bracket amount, no surtax rate or threshold and no withholding percentage. The treaty provisions were read in the convention as amended, protocols included, because the 1975 text of Article 15(1) and Article 6(4)(a) is superseded and still widely quoted 2. The Knesset's record of the Ordinance carries a publication date later than that file 12, which is one more reason no rate or threshold here is offered as current. Confirm any live figure with the Israel Tax Authority before you act on it, and treat every dated figure on this page as of 25 August 2026.
Next step: if any holding in the account is denominated in or linked to a foreign currency, section 88 stops using the consumer price index and uses the exchange rate instead, and every number above changes. Read shekel-measured gains on foreign assets before you compute anything.
Frequently asked questions
Israel taxes the Israeli securities in an Israeli investment account from your first day of residency: the ten-year oleh exemption reaches only assets outside Israel, and section 89(b)(3) sources a gain on an Israeli company's share to Israel. The charge falls on the real capital gain, measured after inflation, at a ceiling of 25%.
Not the Israeli securities inside it. Sections 14(a) and 97(b)(1) exempt a first-time Israeli resident and a veteran returning resident on income and assets outside Israel, and section 89(b)(3) sources a gain on a share in an Israeli-resident company to Israel. So Israeli shares held here are taxed in full from your first day of residency at the ordinary section 91 rates. What decides is where the asset sits, not where the account sits, which is why a foreign security you hold at an Israeli institution is a separate question with its own answer.
Usually not for this income. Section 91(d)(1) would require a report within 30 days of a sale plus an advance payment, but section 91(d)(2C)(a) switches subsection (d) off for an exchange-listed security or a fund unit where tax was withheld from the capital gain under section 164. That switch-off reaches the 30-day report and the advance and nothing else, so you would still file to offset losses held at another payer, to reclaim over-withholding, or where any other duty to file applies to you.
No. 25% is a ceiling, not a flat rate. Section 91(b)(1) applies section 121's ladder with the gain as the top rung and caps it at 25%. A substantial shareholder is capped at 30%, a gain on non-index-linked debt at 15%, and an individual aged 60 or over can reach section 121(b)(1)'s reduced rungs and land below 25%. Nothing in those rates turns on how long you held the security.
Almost never on a modern holding. Section 88 splits the gain into an inflationary amount and a real capital gain, and defines the taxable inflationary amount as only the inflation that would have accrued had the asset been sold on 31 December 1993. Anything bought on or after 1 January 1994 therefore has none, so the whole inflation slice escapes tax. Section 91(c) charges a flat 10% on any taxable inflationary amount that does exist.
Not necessarily. Article 26(1) of the US-Israel convention caps the credit both by the tax you actually paid to Israel and by the limitations US law provides, and Article 26(2), as replaced by the 1993 protocol, sets out the order for a US citizen resident in Israel, including the re-sourcing that makes the credit work. Israel taxes a smaller base because it strips inflation out while US basis is plain cost, so the Israeli tax available as a credit can fall short. Separately, the 3.8% net investment income tax takes no foreign tax credit, though foreign income taxes claimed as a deduction instead may reduce net investment income.
Because section 97(b2) exempts a foreign resident, not the shares. The exemption attaches to your residence status and ends the day you become an Israeli resident, so gains realised after that date fall under the ordinary section 91 charge. Section 97(b3)(3) can carry foreign-asset treatment across the border for a security bought while you were still a foreign resident, but only where the security was not traded on the exchange in Israel at the time of sale.
Sometimes, and only because you were once a foreign resident. Section 88 lets a person who lawfully acquired an asset in foreign currency while a foreign resident request that the acquisition exchange rate be treated as the index. It is a request, not an automatic entitlement. Separately and for everyone, an individual's security denominated in or linked to foreign currency uses the exchange rate as the index by default, with no election needed.
Not if you are genuinely UK non-resident. GOV.UK states that non-residents pay UK tax only on their UK income and not on their foreign income, with residence decided by the Statutory Residence Test. Worth knowing for context: Britain once ran Israel's exact indexation mechanism from the Finance Act 1982, froze it in 1998 and withdrew it outside corporation tax from 6 April 2008.
Three things. It is per-payer, so netting a loss at one institution against a gain at another happens under section 92 in an assessment, not at the till, and carrying an unused loss forward requires a return for the year of the loss. Section 121B(b) keeps the high-income surtax outside section 91(d)'s advance machinery. And it discharges nothing under US or UK law, whose computations run on their own rules.






