עונת הדירוגים לשנת 2012 נפתחת בדירוג של World Tax, פרסום מבית International Tax Review, מדריך המסקר את תחום המיסוי במדינות רבות בעולם לרבות ישראל.
מעבר לסקירה מסודרת על מדיניות המיסוי ושינויים שהתרחשו בתחום בשנה האחרונה, מבצע המגזין גם דירוג על פי איכות לגבי העוסקים בתחום המיסוי, משרדי עו"ד ומשרדי רו"ח כאחד. הדירוג מתבצע על פי דיווחים של משרדי עוה"ד למדריך, וכן בבדיקה אובייקטיבית של מחלקת המחקר של המגזין.
למתעניינים בנושא מדריכי הדירוג, נציין כי מדריך זה שייך לבית ההוצאה לאור של מדריך הדירוג הבריטי IFLR (הוצאת Legal Media Group) ובפועל- מדובר במחלקת מחקר זהה שרק מבצעת ניתוח שונה של הנתונים לתחום המיסוי.
ולאחר הקדמה קצרה זו- לדירוג עצמו שמחולק ל- 4 דירוגי איכות, ובו מככבים המשרדים הגדולים והמובילים בישראל ולצידם משרדי הבוטיק בתחום המיסוי:
קבוצת האיכות הראשונה
משרד רו"ח Ernst & Young
משרד עו"ד הרצוג פוקס נאמן– מוזכרים מאיר לינזן ואלדר בן רובי
קבוצת האיכות השנייה
משרד עו"ד גורניצקי ושות'– מוזכרים פיני רובין, גורי סביר, דניאל פסרמן ואלי אליה
משרד רו"ח KPMG
משרד רו"ח PwC
משרד עו"ד שקל ושות'– מוזכרים משה שקל ועופר אלבוים
קבוצת האיכות השלישית
משרד רו"ח Dwloitte
משרד עו"ד גולדפרב זליגמן- מוזכרים טל עצמון, ירון סבר ורחל אלוש
משרד עו"ד ש. פרידמן– מוזכר דורון שוופה
משרד עו"ד יגאל ארנון- מוזכרים הארי קירש ויאיר בנימיני
קבוצת האיכות הרביעית
משרד עו"ד איתן מהולל– מוזכר ירון מהולל ונועה לב-גולדשטיין
משרד עו"ד אליעזר קפלן– מוזכר אליעזר קפלן
משרד עו"ד גרוס, קלינהנדלר, חודק, הלוי, גרינברג ושות'– מוזכר שמואל בורנשטיין
נתונים נוספים: לדירוג המלא במדריך הדירוג הקליקו כאן, לכתבה בנושא שפורסמה בעיתון גלובס- הקליקו כאן. מעבר לכך, אנו מביאים כאן את הפירוט המלא. כל משרד עו"ד ורו"ח גם זכה לביטוי מילולי אודות פעילותו בשנה החולפת, וכן כמה מילים אודות השותפים הספציפיים.
להלן הפירוט המלא מהמדריך:
Ernst & Young– The well respected international tax and cross border structuring adviser Sharon Shulman leads Ernst & Young's tax practice in Israel. The firm has a full service tax practice and is highly regarded for its work in several areas. Their ability in international tax is crucial to their ability to attract multinational clients from overseas. They noted that Ernst & Young is, "very good on issues of international taxation both for transfer pricing and cross border structuring". Tax advisers also recognise Ziv Manor as one of the market leaders for international tax and the firm also has notable practitioners in other areas. Avi Bibi in indirect tax is widely commended by peers for his practical approach, while Lior Harrari is said to be capable in transfer pricing.
Herzog Fox & Neeman– Herzog Fox & Neeman is one of the largest law firms in Israel and is strong in general corporate and commercial matters. The tax department has expanded this year with the addition of two more associates. The tax practice is capable beyond corporate support and transactional tax issues and covers cross-border structuring, capital markets, transfer pricing, indirect taxes and tax litigation too. The tax team is jointly led by Meir Linzen, who is the firm's managing partner, and Eldar Ben-Ruby, who is a senior partner in tax and head of the firm's fund formation team. Linzen is capable in several areas including M&A, cross-border structuring, customs and currency control matters. Ben-Ruby receives plaudits for his corporate tax advisory work. He specialises in international tax issues with a particular emphasis on cross-border investment funds. The firm has been particularly active in M&A advisory work this year with several high-profile transactions handled by the firm's corporate department on which the tax team provided support. Cross-border tax issues were at the heart of Facebook's acquisition of mobile phone applications developer Snaptu and marked only the second instance of the social network website buying another company outside the US. They also advised PMC-Sierra in its acquisition of Wintegra, a telecommunications infrastructure company. Earn-out provisions in the agreement mean that an additional $60 million may be payable at the end of 2011. This element of the deal posed issues relating to deferred consideration that the tax team had to surmount. The firm's competitors recognise that for clients seeking integrated legal and tax advice Herzog Fox & Neeman is a natural choice. One rival said: "The firm is the best one-stop-shop in Israel for commercial matters where there are also tax issues."
Gornitzky & Co. – Gornitzky & Co's tax department is led by its six partners including the highly regarded litigator Pinhas Rubin, who was promoted to chairman of the firm this year. Some competitors have suggested this has left him unable to handle the same volume of tax work as in previous years, but he has been active in many high profile cases this year and the rest of the department is well regarded across a broad range of tax issues. Partner Gur-Yehuda Savir is a practitioner repeatedly singled out by peers for corporate tax and capital markets and sits on both the tax committee and the entities and capital markets committee of the Israel Bar Association. Daniel Paserman is also a member of the tax committee and a member of the corresponding body of the Israeli Accounting Board. Tax litigation for the firm this year included representing companies affected by the government's proposed special tax on the oil and gas sector after the discovery of a large gas field off the Israeli coast. The team led by Rubin represented the companies' interests throughout the legislative process, culminating in an application to the Supreme Court for declaration of the proposed law as unconstitutional. The firm is also capable in tax planning and cross border structuring, with Eli Elya identified by his peers as first-class in those practice areas. The firm's work this year has included advising a consortium of 15 Israeli public companies and institutional investors on the restructuring and refinancing of their purchase of 16 Hilton hotels in the UK. This required analysis of the best structures to use and attention to the interaction of Israeli, Gibraltarian, Jersey and English law from a tax perspective.
KPMG– KPMG has a practice in Israel consisting of six partners and 95 fee earners. The firm counts major Israeli companies as well as multinationals among its clients. The tax department is led by Eran Shalev with a partner in charge of either a service line or certain industry sectors within those service lines. Several of the partners are capable and specialised in domestic corporate tax issues, though each has a different focus. Nisim Cohen has particular expertise in real estate tax issues while Ilan Ezra is focussed on M&A and tax issues within the technology sector. Eli Piterman and Yifat Shaaya are capable in domestic corporate tax but Piterman also handles indirect taxes. John Fisher and Dina Pasca-Raz deal with international tax issues for the firm with particular attention paid to cross-border structuring. There is a strong link between its audit practice and its tax practice and notes that much of their tax work is done for companies audited by the firm.
PwC– PwC's Israeli tax practice is headed by Gerry Seligman who competitors think is highly competent for cross-border structuring matters. The firm provides a full range of tax services for clients in Israel , including international work in the region through the PwC network. The firm also has a good reputation for indirect tax work, which is an important issue in Israel in the real estate sector. In that area, Shay Shalhevet is singled out by his peers for the consistent quality of his advice. Vered Kishner is the partner responsible for transfer pricing, an increasingly important issue for companies operating in Israel as the tax authorities are said to be stepping up their scrutiny of intra-group financing.
Shekel & Co.– Shekel & Co has expertise in corporate tax, international tax, indirect tax, real estate tax and contentious tax issues. The firm's ability in corporate law, commercial law and real estate facilitates means the tax team can provide integrated tax expertise and advice for clients. Moshe Shekel heads the tax department which now comprises nine partners and 13 other fee earners. Tax controversy and disputes is a distinguishing strength for the firm. Shekel remains active in the practice and this year led the team which settled a 15 year-dispute for Israeli gas company Amisragaz that was valued at some $60 million. The taxation of advances and deposits was the central issue in the settlement. This was the only case of three on the same issue which was settled, the others were decided in favour of the Israeli Tax Authority (ITA). Ofer Elboim represented telecommunications company Bezeq in the Supreme Court in a dispute over the taxation of real estate leases. The court overturned the district court ruling and allowed for the reclassification of real estate lease transactions. With a precedent value in the hundreds of millions it is expected to become a landmark case in Israeli tax law. The firm now represents every Israeli telecommunications company except one and all of the nation's gas companies. It has developed a strong reputation among international funds as a result of the work done for Apax last year and now handles tax work for nearly 20 clients in this sector.
Deloitte– Yitzchak Chikorel leads Deloitte's Israeli tax practice of nine partners and 80 other fee earners. The firm is known for its cross-border structuring work and corporate tax capability. Chikorel is recognised by peers as a good international tax adviser. Deloitte advised on the largest joint venture in Israel this year; this was one of many M&A transactions it advised on in a quiet market. The transfer pricing service line has seen a significant increase in the volume of work this year as clients seek advice in light of increased scrutiny from the tax authorities.
Goldfarb Levy Eran Meiri Tzafrir & Co.– Goldfarb Levy Eran Meiri Tzafrir & Co is one the largest law firms in Israel and has a tax practice focused on corporate tax issues, but with capability in international tax, tax controversy, capital markets and employee incentives. Partner Tal Atsmon leads the firm's tax group and advises on matters across corporate tax, capital markets, international tax and structuring. He is a well known figure within the Israeli tax market and has written a number of articles. He is also a member of the tax legislation committee of the Israeli Bar Association. Other partners Yaron Sever and Rachel Allouche both specialise in corporate tax and capital markets and Sever is skilled in employee incentives too.
S Friedman– The law firm S Friedman is well established in corporate and commercial law and has a tax department that is capable of advising on most tax issues. Doron Schweppe leads the tax department and is a specialist in international tax, real estate, corporate tax and joint venture company tax issues. The firm has a well established referral network across the Americas, Europe, Asia and Africa providing them with a consistent flow of international tax work. Much of this international work relates to real estate, capital markets and the shipping industry where the firm has a strong reputation.
Yigal Arnon & Co.– Yigal Arnon & Co has a tax department providing services in corporate tax advice, international tax, M&A, cross-border structuring, tax litigation and indirect tax. Partner Harry Kirsch leads the tax department and is well regarded by his peers for his work in both corporate tax advisory and M&A matters. His fellow partner Yair Benjamini has experience in international tax, real estate tax and indirect tax in particular, though is capable in general corporate tax matters, too. The firm's department is completed by two associates. Their work this year has included advising clients on the ITA's rulings on equity grants made to employees which are particularly important for companies using employee incentive schemes involving shares.
Eitan Mehulal– Eitan Mehulal is a law firm with a well regarded tax department. The firm handles M&A tax issues, cross-border transactions and structuring, indirect taxes, tax opinions and tax controversy. The firm's senior partner Yaron Mehulal is a well respected figure in the tax market, having co-written four volumes of the Israeli tax publication 'Income Tax' and being a former lecturer on tax at Tel Aviv University. Mehulal is also a member of the tax committee of the Israeli Bar Association and specialises in tax advice for both inbound and outbound investments and transactions. Noa Lev Goldstein, the leader of the tax department, is a former ITA division manager, providing the firm with good links to the tax authorities and detailed knowledge of legislation and its enforcement. Goldstein has particular ability in tax planning and obtaining tax rulings and also provides professional opinions.
Elieser Kaplan– Elieser Kaplan is a boutique tax law firm led by the highly respected practitioner Elieser Kaplan who is a former lecturer in international tax at Tel Aviv University. He is supported by two associates and the firm focuses on international tax, tax planning and structuring and tax controversy issues. It is also capable in more straightforward issues of corporate and transactional tax, though the firm's focus is on the more technical aspects of cross-border matters.
Gross, Kleinhendler, Hodak, Halevy, Greenberg– Gross, Kleinhendler, Hodak, Halevy, Greenberg's tax practice advises clients on employee and executive incentives, M&A tax, international tax planning and structuring, tax controversy and VAT. The department head is partner Samuel Borenstein, who is supported by 25 other tax practitioners, which represents modest growth from last year with the addition of one fee earner.