The Bottom Line: The Israel Tax Authority is removing significant bureaucratic barriers for Israeli investors operating globally. Effective immediately, funds can be transferred abroad with an automatic exemption from withholding tax based solely on a bank declaration (Form 2513/2). The new directive expands the "Green Track" to include a much wider range of countries (including CRS signatories) and new investment channels, most notably digital assets (Crypto), without the need for specific approval from a Tax Assessor.
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Executive Summary

• Expanded Destinations: The exemption track is now open for transfers to any country that has a Tax Treaty with Israel or is a signatory to the CRS (Common Reporting Standard) agreement.
• Crypto & Digital Assets: For the first time, funds can be transferred to foreign crypto exchanges (subject to KYC) via the declaration track, bypassing the need for individual tax rulings.
• Bureaucracy Slashed: The process is handled entirely through the banking system (digital or branch), eliminating the need to approach the Tax Authority for standard transactions.
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The Background: The Withholding Tax Barrier

Under Section 170 of the Israeli Income Tax Ordinance, any payment to a non-resident is subject to a mandatory withholding tax of 25% (for corporations) or more, unless a specific authorization reducing or exempting the tax is obtained from a Tax Assessor. Historically, this requirement created a heavy bureaucratic burden on investors and service consumers, forcing them to approach the ITA for every transaction, even when it was clear no tax was due (e.g., purchasing a private apartment abroad).

In 2017, the ITA launched the "Declaration Track" (Form 2513/2), allowing banks to process transfers based on a client's declaration. However, this was limited to a narrow list of countries and transaction types. Now, recognizing the need to facilitate economic activity, the ITA is dramatically expanding this track.
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The Legal Issue

The core challenge for the regulator was balancing the prevention of capital flight and tax evasion with the need to enable fluid global business operations. The ITA had to determine which destination countries and transaction types are "safe" enough to allow transfers without a pre-audit by a Tax Assessor, relying instead on the taxpayer's declaration and international information-sharing mechanisms.
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The New Directives (December 2025)

According to the new announcement, the criteria for using Form 2513/2 have been updated as follows:

1. Permitted Destination Countries

The barrier has been significantly lowered. Funds can now be transferred to a beneficiary who is a resident of (and holds a bank account in):

• Any country that has a Double Taxation Treaty with Israel.
• Any country that is a signatory to the CRS (Common Reporting Standard) agreement for automatic exchange of information.
  Significance: This opens the track to dozens of additional jurisdictions, including many financial hubs that previously required specific approvals.

2. Permitted Transaction Types

The list of approved purposes has been expanded to include a major addition:

• Purchase of Digital Assets (Crypto): Funds can be transferred to foreign trading platforms (Exchanges), provided they perform a "Know Your Customer" (KYC) process.
• (This is in addition to existing categories: Purchase of real estate abroad, purchase of tradable securities, tourism services, tuition fees, etc.)

3. The Operational Process

The taxpayer fills out the updated form directly at the bank (or via the bank's app). The bank verifies the form is complete and executes the transfer. The form is retained by the bank and transferred to the ITA upon demand for future audits.
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Practical Takeaways for Investors

1. Time and Cost Efficiency: For private investors and companies, this saves days of work and waiting periods. There is no longer a need to file requests via the ITA's system or visit a Tax Assessor for standard international investments.
2. Legitimacy for Crypto: The official inclusion of digital asset purchases in the "Green Track" is a positive signal from the regulator. However, note the KYC condition – transfers to anonymous private wallets or unregulated exchanges will still likely require specific approval (which remains difficult to obtain).
3. Declarant Liability: The procedural easing shifts the burden of responsibility to the taxpayer. Signing Form 2513/2 is a binding legal declaration. If an audit reveals the transaction was actually taxable (e.g., payment for business services that are not exempt), the payer faces exposure to fines, interest for failure to withhold tax, and potential criminal liability for false declaration.
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FAQ (Questions & Answers)

Q: Can the bank still refuse the transfer even if I fill out the form?
A: Yes. Banks are subject to their own strict Anti-Money Laundering (AML) and risk management regulations. The Tax Authority's form solves the tax withholding issue, but it does not mandate the bank to execute a transfer if they suspect the source of funds or other compliance risks.

Q: Can I use this form to transfer funds to my own company abroad (Owner's Loan)?
A: You must check the specific transaction categories on the form carefully. Investment in share capital is generally permitted, but granting loans may require an examination of whether the transaction involves "deemed interest" which is taxable. When in doubt, consult a tax advisor.

Q: What qualifies as a CRS country?
A: This refers to a list of over 100 jurisdictions committed to sharing financial data, including most developed nations and many offshore financial centers (such as the Cayman Islands, BVI, etc.). The list is updated periodically by the OECD and the ITA.

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Updated list of 104 CRS countries for 2024-2025 (to which funds can be transferred under this track): Click here