A practical guide for American and other foreign founders: choosing your structure, the registration process, the management-and-control tax trap that catches people who run a US company from Israel, and what setup gets it right from day one.
If you're an American (or other foreign) founder, the usual vehicle for doing business in Israel is an Israeli private limited company (Chevra Ba'am). Depending on your situation, common structures are: owning the Israeli company directly as an individual; holding it under a US C-corporation; running an Israeli branch of your existing US company; two parallel companies; or a US LLC with a services agreement to an Israeli company. For a US owner, the Israeli company is usually a Controlled Foreign Corporation, which adds a US tax layer (GILTI, Subpart F, Form 5471) on top of Israeli corporate tax. Much of that can often be reduced with the right planning. The full US-side treatment, and which structure fits, is on our Israeli Company for US Owners page.
Forming an Israeli company (Chevra Ba'am) means clearing a name, drafting the articles of association, setting the share structure and board, and registering with the Companies Registrar.
If the company has more than one founder, a watertight founders' agreement between the partners is strongly recommended, and in some cases required. It sets out ownership, roles, decision-making, and how a partner exits, and the tax authorities may ask to see it.
Under Israeli tax law, a company is treated as an Israeli resident if it was incorporated in Israel, or if its control and management is exercised from Israel. The second test catches many Americans by surprise: a company registered in Delaware can still be an Israeli tax resident if it is actually run from here.
The test looks at where the real decisions are made, not where the company is registered. That means where strategy is set, where the board meets and decides, and where the business is managed day to day. If those decisions are made by you, from your home in Israel, the company may be managed and controlled from Israel.
An American who moves to Israel and keeps running a US company from here may, without intending to, make that company an Israeli tax resident. Its profits could then be exposed to Israeli corporate tax, on top of its US obligations. The new-oleh exemption applies to your personal foreign income. It does not automatically protect a company that becomes an Israeli tax resident.
This is assessed case by case, based on how the company actually operates. The planning levers include where and how decisions are made and documented, who sits on the board and where they are, and in some cases changing the structure. Because the facts decide the outcome, it should be reviewed before or soon after you move, not after a tax assessment arrives.
Related: Israeli Company for US Owners (the US-tax side) and Israeli Resident Director Services (a local director as part of the planning).
The government fees for forming an Israeli company are set by regulation and updated at the start of each year, so we quote the current figures for your case rather than fixed numbers here. The one-time registration fee to the Companies Registrar has been in the range of a few thousand shekels in recent years, and is lower when filed online. The annual fee to the Registrar runs in the range of roughly 1,300 to 1,800 shekels a year, and can change from year to year. Opening the tax files carries no government fee. The current amounts are published by the Israel Corporations Authority (Rashut HaTagidim). Beyond the government fees, the professional fee for the accounting and legal support is set individually, based on scope.
We handle the whole formation: choosing and clearing the name, drafting the articles, setting the share structure, registering the company, and opening the tax files. For foreign and American founders we also coordinate the US-side structuring and the management-and-control planning, so the company is set up correctly from day one.