From an Israeli Perspective – Implications on Tax Residency of Individuals and Corporations in the Current Health Crisis
COVID 19 and the unprecedented measures such as travel restrictions and quarantine requirements imposed globally by governments, including Israel, to control the spread of Corona have disrupted travel plans of individuals.
Individuals are not able anymore to freely move between countries, and sometimes have difficulty to leave and return to their home country.
This has raised a series of international tax questions on residency of individuals, on residency of corporations, the establishment of permanent establishments and the allocation of taxing rights between jurisdictions.
For example the prolonged stay of a person in Israel might expose that person to the claim that he/she has become a resident of Israel and therefore his/her entire worldwide income is subject to tax in Israel. A prolonged stay also might have an impact on the allocation of taxing rights with respect to mixed income of new immigrants.