SHEMESH CPA

Relocation and Exit Tax (Section 100A)

When an Israeli resident ceases to be resident, Section 100A treats their assets as sold one day before departure, creating an exit tax on the deemed gain. The taxpayer can pay immediately or defer until the asset is actually sold, in which case the gain is apportioned linearly between the years as a resident and as a non-resident. Assets exempt for a resident are generally exempt here too.

The Deemed Sale Principle

To prevent tax avoidance where residents accumulate value in Israel and then sell assets tax-free after becoming non-residents, Israel imposes an Exit Tax.

Payment Options

The taxpayer has two choices:

  1. Pay Now: Pay the tax on the theoretical gain immediately upon departure.
  2. Defer Payment: Defer the tax payment until the actual sale of the asset in the future. In this case, the tax will be calculated proportionally (Linear Calculation) based on the time spent as an Israeli resident vs. non-resident.

Exemptions

Generally, assets that would be tax-exempt if sold by an Israeli resident are also exempt from Exit Tax. Specific rules apply to options (102 plans) and real estate.

Do I have to pay exit tax on the day I leave Israel?

No. You can choose to pay on the deemed gain immediately, or defer payment until you actually sell the asset.

How is the tax calculated if I defer it?

On the actual sale, the gain is apportioned linearly according to the time the asset was held while you were an Israeli resident compared with the time as a non-resident.

Which assets are exempt from exit tax?

Generally, assets that would be exempt if sold by an Israeli resident. Specific rules apply to Section 102 options and to real estate.

When does Israel exit tax apply?

Israel exit tax (section 100A) can apply when an Israeli resident ceases to be a resident while holding assets, and can also arise when a company relocates. Timing and valuation matter, so the position is best reviewed with an Israeli tax advisor before the move, not after it.