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מיסוי כללי

Deadline extension for reporting periods in Light of the "Iron Swords" War

המאמר התפרסם לראשונה באתר 

3.12.2023

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Example: Accordingto the provisions of Section 150(a) of the Income Tax Ordinance, an appealagainst the assessment must be filed within 30 days of the date of service ofthe assessment notice, unless a request for an extension of the deadline hasbeen filed and approved for a justified reason.

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Litigation

Deadline extension for reporting periods in Light of the "Iron Swords" War

December 3, 2023

The article was first published in 

On November27, 2023, the Knesset plenum approved the "Iron Swords" (ProvisionalOrder – Extension of Periods and Delay of Deadlines) (Tax Procedures andAssistance Grants) Law, hereinafter referred to as the "Law". Butwhat exactly did the Law say? In this article, we will organize and review allthe relevant provisions of the Law.

Purpose ofthe Law

The purposeof the Law is to extend the validity of limited time periods set in tax lawsfor various procedures between taxpayers (the public) and the Israel TaxAuthority.

To implementthe purpose of the Law, it is stipulated that if the start date of the timeperiod for performing a specific action (in accordance with the provisions ofthe existing law), falls before the end of the "determining period"(Section 1 of the Law: a period of three months beginning on October 7, 2023)and the last day for performing the specific action, falls during the"determining period" or within two (2) months after it (Section 2(a)of the Law), then the last day for performing the specific action will bepostponed by three (3) months.

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Example: Accordingto the provisions of Section 150(a) of the Income Tax Ordinance, an appealagainst the assessment must be filed within 30 days of the date of service ofthe assessment notice, unless a request for an extension of the deadline hasbeen filed and approved for a justified reason.

Thus,if the start date of the 30-day period for filing the appeal is October 1, 2023(and ostensibly, according to the provisions of the Ordinance, we had to filethe appeal until 30 days from that day – November 1, 2023), now, in accordancewith the provisions of the Law, since the deadline for filing the appeal fallswithin the determining period (3 months), then the deadline for filing theappeal will be postponed until February 1, 2024.

Extensionof Periods for Single-Family Homes and Qualified Residential Properties in theProperty Tax Law (Special Order)

Becauseprocesses related to selling a property require a period of preparation, it isproposed to allow an extension of three months from the end of the determiningperiod, or three months from the date on which the relevant period was supposedto end according to the provisions of the Property Tax Law, whichever is later;and all of this, if the period set for the taxpayer according to the provisionsof the Property Tax Law, in whole or in part, falls within the determiningperiod, and this even if the end date of the period set as such does not fallwithin the determining period. In this case, anyone for whom part of thepreparation period available to them according to the provisions of theProperty Tax Law falls within the determining period, will have threeadditional months to sell the property.

Explanation: Someone forwhom the period according to the Property Tax Law is supposed to end on October8, 2023, will have three additional months from the end of the"determining period", meaning - until April 7, 2024.

Someonefor whom the period according to the Property Tax Law is supposed to end at theend of the "determining period", meaning on March 1, 2024, will havethree additional months from that day (June 1, 2024).