Moshe Mizrachi, Noach, Kriegel Law Firm

Israeli boutique tax law firm providing business and individuals with comprehensive taxation services. The firm’s partners specialize in designing tax concepts, solving complex issues, and devising creative strategies and solutions to meet clients’ needs. The firm was founded in 2011 by former Israel Tax Authority legal advisor Adv. (CPA) Moshe Mizrachi, former Tax Authority Professional Director Adv. Eldad Noach, and former Tax Authority Encouragement Laws Legal Bureau Director Adv. Amit Kriegel. The partners were instrumental in making and creating some of the most important decisions and policies at the Tax Authority during their tenure. The complex and unique experience they gained throughout this period puts them in a strong position to offer quality, in-sight, and expertise of the highest standards. The firm presented and represents public and government companies, non-profit organizations, financial institutions, industrial enterprises, and leading shareholders, international companies, and foreign investors in Israel, and supports clients in banking, finance, infrastructures, energy, aviation, real estate, industry, and commerce and from the non-profit sector. Personal Attention to a Client from Authoritative Partners The expertise, professional knowledge and extensive experience accumulated by the partners and the combination of forces as a synergistic team, and “out-of-the-box” thinking offer the firm’s clients in-depth and creative legal solutions in tax law. This is combined with personal attention to the client and excellent legal service from the firm’s senior partners.

The Partners

Adv. (CPA) Moshe Mizrachi, Founding Partner - Moshe is one of Israel’s leading tax attorneys. He was Legal Advisor to the Tax Authority from 2004-2011. Previously he was Legal Advisor to the Customs and VAT Department and Director of the Jerusalem District Fiscal Prosecutor (civil and criminal). His considerable and profound knowledge with all aspects of the law and his unique and creative perspective is expressed while representing his clients vis-à-vis tax authorities, presenting creative solutions, both in the civil field, as well as in the criminal one, and in essential cases – by combining and integrating them, and managing complex litigation cases. Adv. Mizrachi is considered to be acceptable in the eyes of decision makers at the tax authority, as profoundly sensible.
Adv. Eldad Noach, Partner - Eldad maintains vast knowledge and experience in a wide variety of matters pertaining to tax. He was Professional Division Director heading up the Tax Authority’s Mergers and Acquisitions Department (2007-2011). As a Departmental Director, he was responsible for the following units: structural change, capital markets, employee options, and provident funds. Adv. Noach’s vast knowledge in various tax matters, and his in-depth acquaintance with the tax authority’s thinking patterns and decision-making processes, brought him to lead innovative systematic tax decisions regarding restructuring (pertaining to restructuring partnerships), and as a representative for the hedge funds union – regarding investments funds.
Adv. Amit Kriegel, Partner - Amit is considered to be one of Israel’s leading tax attorneys. He was the manager of the Law Encouraging Capital Investment Dept., and served as the Legal Advisor to the Large Enterprises Assessor, Dan Region Assessor and a Real Estate Taxation office. Since the foundation of the firm, Adv. Kriegel handled a variety of complex legal matters, regarding income tax, VAT and excise tax, and encouragement laws, pertaining to in-depth opinions, which influenced the market vis-à-vis the tax authority.

Practice Areas

Income Tax - Corporate and Individual Tax: The firm provides legal support to companies and individuals in all tax aspects and acts in assessment procedures and court appeals. The firm is also involved in analysis of tax aspects regarding the transactions’ planning stage, including unique and complex transactions. In addition, the firm handles receipt of pre-rulings for professional departments and provides legal opinions, in representation of assessment and comprehension proceedings, and providing legal opinions in various fields. Some of the opinions that the firm provided regarding income tax became canonical opinions, in the sense that the market’s largest firms, leading accounting firms and the institute of certified public accountants thought that they maintain grounds for fundamental claims pertaining to tax assessment.
Taxation Litigation - The firm is renowned for representation in appeal proceedings in district courts and in the Supreme Court. The firm represented leading cases in district courts and in the Supreme Court, which required thorough analysis, both factually as well as legally, and became central innovative laws. In many of the cases, the tax authority was required to reexamine its position, due to the legal discussion, and on occasion, even the law itself.
International Taxation - International taxation focuses on trust structures, tax benefits that were set for new immigrants and returning residents, the report requirements to the tax authorities, and tax arrangements for foreign companies with Israeli links, both pertaining to foreign investors working in Israel, and Israelis who maintains activity abroad. In all these matters, out firm provides the required consulting.
Taxation of Non-Profit Organizations, Associations and Public Institutions - Our firm advises large non-profit organizations, institutions of higher education and workers’ committees working in the fields of health and welfare, as well as philanthropic funds in the unique aspects relating to the unique tax arrangements that apply to them, both by the Income Tax Ordinance and by the VAT Law. The firm represents these entities before the Income Tax Authorities and VAT for the purpose of making preliminary taxation decisions regarding the classification of the entity and in litigation in assessment proceedings and in the courts.
Tax Offenses (Criminal Taxation) - Tax offenses include attaining plea agreements and submission of requests for ransom. In prominent cases handled by our firm in recent years, when allegations of tax offenses and money laundering offenses were raised, the firm succeeded in formulating integrated arrangements that led to the regulation of the criminal aspects, this includes aspects relating to the forfeiture of property and the disputes relating to the civil tax assessment.
VAT - In recent years, our firm represented leading cases regarding services provided to international groups that work abroad to financial corporations regarding disagreements pertaining to profit tax determination, and to hotel and tourist companies that maintain unique VAT aspects.
Structural Changes (M&As, and Transfer of Assets) - Advising clients of restructuring opportunities in order to enable holdings and economic-legal considerations within the framework of ongoing transactions in Israel and abroad. The restructuring field is headed by Adv. Eldad Noach, who formerly served as the manager of mergers and divisions at the tax authority, and one of the leading designers of the tax authority’s policy in this field.
Encouragement Laws, Incentives, and R&D Laws - The firm supports and advises regarding encouragement laws, including entitlement solutions, requests for government authority approvals (Economy Ministry Chief Scientist, Investment Center and others), tax benefits for R&D activities, benefits for leasing premises and renewable energy ventures.
COVID-19 and Compensation for “Iron Swords” War Damages– In recent years, our firm has been representing large entities regarding their entitlement to compensation granted by the state in connection with economic damage during the Corona pandemic. Our office also deals with filing claims and representing large corporations that have been affected by war damages.
Voluntary Disclosure Procedures - Many Israelis still maintain bank accounts abroad. The income from these bank accounts may be subject to tax in Israel. The tax authority increases enforcement in this matter, and even has offered in the past and is expected to offerin the future lenient tax arrangements, within voluntary disclosure proceedings, which offer immunity from a criminal trial, while arranging civil tax debt. Our firm represented many clients in various voluntary disclosure proceedings.
Real Estate Taxation - Our firm represents individuals and corporations on all topics related to real estate tax including combination deals, selling homes, urban renewal, trusts, company liquidations, transferring land to shareholders, allocating rights to property associations, etc.
Excise tax – Our firm accompanies leading gas manufacturers, including green gas, regarding attaining manufacturing licenses, opinions pertaining to the implementation of excise tax rules, and regular accompanying vis-à-vis excise tax authorities. In addition, the firm works with policy makers within the tax authority regarding regulation concerning excise tax, for the promotion of legislative amendment in this field.