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When will it be possible (if at all) for the tax authority to provide information to an external consultant under section 105 of the real estate taxation law?

59579-02-11

29.11.2023

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When will it be possible (if at all) for the tax authority to provide information to an external consultant under section 105 of the real estate taxation law?

59579-02-11

Nov 29, 2023

Real Estate Taxation

Emphasis: For the provision of information to appraisers acting under the law, in the context of Section 105, see Income Tax Implementation Instruction No. 7/2004 - "Provision of information to real estate appraisers - government appraisers and appraisers under the Planning and Building Law, 1965."

Clarification: In contrast to Section 105 of the Income Tax Law, Sections 231 and 232 of the Income Tax Ordinance impose a duty of confidentiality on "whoever is employed in its implementation" of the Ordinance. This may include external consultants or experts hired by the Tax Authority.

Section 105 of the Income Tax Law does not impose a duty of confidentiality on external consultants or experts. However, the court in the case of Belas held that the Minister of Finance may grant permission to disclose information to external consultants or experts for the purpose of obtaining their assistance in the assessment procedures.