Foreign shareholders worldwide: United States · United Kingdom · Canada · France · Australia · Germany · Switzerland · South Africa · Belgium · and across the diaspora.
Foreign shareholders can sell shares of Israeli public companies - even without an active Israeli bank account. Under Section 97A of the Israeli Income Tax Ordinance (5721-1961), non-resident shareholders are generally exempt from Israeli capital gains tax on TASE-listed securities. The process is handled remotely through a notarized Power of Attorney with Apostille.
Eliyahu & Co. Law Office is a boutique Israeli law firm specializing in cross-border legal services for foreign shareholders, non-residents, and international clients - with particular focus on the sale and transfer of Israeli public company shares, trustee-held securities, private company shareholdings, and the broader spectrum of Israeli securities matters arising in international contexts. Over 19+ years of practice, the firm has built substantial experience representing shareholders across every scale and complexity - from individual non-resident owners of small holdings to estate-related transactions involving multi-million-dollar positions in TASE-listed companies, dual-listed securities, and shares held through major Israeli trustee companies including Resnick Paz Nevo, IBI Trust, Mizrahi Tefahot Trust, Bank Leumi Trust, Bank Hapoalim Trust, and Discount Trust.
Our specialization spans every legal aspect of foreign-shareholder securities transactions: Power of Attorney preparation with Apostille for execution abroad, direct liaison with Israeli trustee companies and licensed brokers, tax planning under Section 97A of the Israeli Income Tax Ordinance for non-resident capital gains exemption, coordination with the Israel Tax Authority for tax clearance certificates, execution of share sales on the Tel Aviv Stock Exchange, structured handling of Section 102 employer-grant shares, transfer documentation for the Israel Securities Authority, and coordination with foreign tax counsel for IRS Form 8938, FBAR, HMRC, CRA and equivalent international filings. The firm also handles the specialized procedures required when shareholders no longer maintain an active Israeli bank account - routing proceeds through the firm's regulated client trust account directly to foreign destinations.
The firm is led by Adv. Reut Eliyahu, founding attorney and licensed Israeli notary, who holds an LL.B and an MBA with Marketing Specialization, has been a member of the Israel Bar Association since 2007 (License No. 47439), and is also a registered arbitrator. The combination of legal training, formal notarial authority, business administration credentials, and 19+ years of direct practice in cross-border Israeli matters allows the firm to handle every dimension of a foreign-shareholder transaction in-house: legal strategy, document preparation, notarization, trustee coordination, tax planning, and post-transaction registration. Adv. Eliyahu handles each securities matter personally - from initial consultation through funds received in the shareholder's foreign account - providing the continuity that cross-border clients value most.
Israeli shares sit in foreign portfolios for many reasons - old employer grants, family transfers across generations, inherited investments, or simple migration history. Each scenario requires its own legal approach. Below are the most common patterns we handle for non-resident shareholders.
Non-residents holding shares of Israeli companies listed on the Tel Aviv Stock Exchange - including Israel Corporation, Bezeq, Teva, Bank Leumi, Bank Hapoalim, and others. Whether the shares are held directly or through a trustee, we manage the full legal process for sale and proceeds release.
Beneficiaries who inherited Israeli shares from a parent, sibling, or relative - and now live abroad. Often the shares are discovered during estate administration, sometimes in trustee accounts the heirs never knew existed. We handle the inheritance angle alongside the securities transfer.
Israelis who relocated to the United States, Canada, the UK, or elsewhere years ago - typically without closing out all Israeli financial positions. Also includes non-Israeli individuals or entities who invested in an Israeli company years ago and now want to liquidate the position.
Shareholders whose securities sit in Israeli trustee accounts - Resnick Paz Nevo, IBI Trust, Mizrahi Tefahot Trust, Bank Leumi Trust, Bank Hapoalim Trust, Discount Trust - while the owners no longer have an active Israeli bank account. This is one of the most common patterns we handle.
The legal framework governing non-resident shareholders in Israeli public companies is well-established. These are the core statutory and regulatory references that determine how the sale of shares is taxed and processed.
Israeli Income Tax Ordinance - Capital gains exemption for non-resident shareholders on TASE-listed securities
Standard Israeli capital gains rate - Applied to Israeli residents (non-residents exempt under Section 97A)
Potentially available to qualifying non-residents - Subject to specific conditions under Israeli tax law
Stock options & employee shares - Specific tax treatment when shares originated from employer grants
Typical timeline - From engagement to funds received in foreign account
Required from ITA - Confirms non-resident exemption before sale proceeds are released
Most Israeli public company shares held by foreign shareholders are managed by trustee companies - not held directly by the shareholders themselves. We have established working procedures with all major Israeli trustees, which streamlines the legal process significantly.
If your shares are held by one of these trustees, the legal framework is familiar to us - and our liaison procedures are already in place.
Resnick Paz Nevo
רזניק פז נבו
IBI Trust Services
אי.בי.אי נאמנויות
Mizrahi Tefahot Trust
נאמנות מזרחי טפחות
Bank Leumi Trust
נאמנות בנק לאומי
Bank Hapoalim Trust
נאמנות בנק הפועלים
Discount Trust
נאמנות דיסקונט
Free initial consultation - by email, phone, or Zoom - to assess where the shares are held, your options, and the realistic timeline. No obligation.
Selling Israeli shares as a non-resident is rarely a single transaction - it involves coordination across multiple Israeli entities, tax authorities, and (often) the international banking system. We handle every step end-to-end.
Sale of shares listed on the Tel Aviv Stock Exchange - execution through licensed Israeli brokers, with all regulatory compliance for non-resident shareholders.
Direct coordination with Resnick Paz Nevo, IBI Trust, Mizrahi Tefahot Trust, and other Israeli trustees - from verification of holdings through release of sale proceeds.
Off-market transfers of private Israeli company shares - including transfers between family members, sales to third parties, and complete share dispositions.
Shares of Israeli companies (dual-listed or otherwise) held through foreign brokers - coordination of Israeli tax certificates and Israeli regulatory documentation.
Government and corporate bonds, debentures, and structured securities held by foreign owners - verification, sale, and proceeds transfer.
Israeli mutual fund units held by non-resident investors - redemption coordination, tax clearance, and proceeds release to foreign accounts.
Shares of "Chevrot Gush Chelka" - Israeli companies whose primary asset is real estate. Specialized handling for the property-attributed gain rules.
Section 97A exemption certificates from the Israel Tax Authority, coordination with foreign tax counsel, and documentation for IRS Form 8938, FBAR, and equivalent foreign filings.
The presence (or absence) of an active Israeli bank account affects how the sale proceeds are routed - but it does not prevent foreign shareholders from selling. Both paths are entirely workable.
| With Active Israeli Account | Without Israeli Account | |
|---|---|---|
| Timeline | 3-5 weeks typical | 4-8 weeks typical |
| Power of Attorney | Notarized + Apostille | Notarized + Apostille (often expanded scope) |
| Proceeds Routing | Direct to Israeli account, then wire abroad | Through firm trust account, then direct to foreign account |
| Tax Certificate | Required (Section 97A) | Required (Section 97A) |
| Trustee Liaison | Direct with trustee + bank | Direct with trustee, firm acts as proceeds custodian |
| Foreign Currency | Convert at Israeli bank or on wire | Conversion handled at transfer to foreign account |
| Documentation | Standard suite | Extended (additional bank compliance documentation) |
Every engagement follows a clear, sequenced process. You always know which stage your matter is in, what is happening next, and the realistic timeline for each step.
Free consultation by email, phone, or Zoom. We confirm where the shares are held - direct registration, trustee account, broker account, or other arrangement. We verify tax residency of the shareholders, review any existing documentation (share certificates, trustee statements, prior tax filings), and estimate the transaction value. At this stage we identify any complications early - joint ownership questions, prior gift transfers, employer-grant origin (Section 102 implications), or estate-related issues.
We draft a customized Israeli Power of Attorney in English, tailored to the specific transaction - including authority to liaise with the trustee, execute the sale, obtain tax certificates, and transfer proceeds. The POA is executed before a local notary in the shareholders' country of residence, then apostilled (or authenticated, depending on jurisdiction) and sent to our firm in Israel. We provide detailed country-specific instructions to ensure the document is properly executed the first time.
A clear written engagement letter outlining the scope of services, the custom fee structure (based on transaction value and complexity), and the projected timeline. Every cost item is identified upfront - legal fees, government certificate fees, broker fees if applicable. No engagement begins until the agreement is signed and you have full clarity on every cost.
Direct communication with the entity holding the shares - typically an Israeli trustee company (Resnick Paz Nevo, IBI Trust, Mizrahi Tefahot Trust, Bank Leumi Trust, Hapoalim Trust, Discount Trust) or licensed broker. We verify the share ownership, confirm the current holding structure, and prepare for sale execution. For trustee-held shares, this is where the firm's established relationships streamline the process significantly.
Execution of the share sale - typically on the Tel Aviv Stock Exchange for public company shares, or off-market for private placements. Before the proceeds can be released, we obtain a tax certificate from the Israel Tax Authority confirming non-resident status and Section 97A exemption eligibility. We provide all documentation in a format suitable for the shareholder's home-country tax filings.
Net proceeds are wired directly to the shareholders' foreign bank account - in USD, EUR, GBP, CAD, or other major currency. Where multiple beneficiaries are involved (siblings, co-heirs, joint owners), proceeds can be split across separate accounts in different countries. Complete transaction documentation is provided for foreign tax reporting requirements (IRS Form 8938, FBAR, HMRC equivalents).
This is the single most common obstacle foreign shareholders encounter when trying to sell Israeli shares - and the reason many simply give up. It's also entirely solvable.
Many foreign shareholders no longer have an active Israeli bank account. They may have closed it years or decades ago when leaving Israel - or they may have never had one (as in the case of inherited or family-gifted shares). At the same time, Israeli banks have become increasingly reluctant to open new accounts for non-residents due to FATCA, CRS, and Israeli anti-money-laundering compliance burdens. The result: a non-resident shareholder may hold shares worth significant value but have no clear path to receive the proceeds.
Sale proceeds are routed through our firm's client trust account in Israel - a regulated, fully-documented escrow arrangement compliant with Israel Bar Association requirements. From there, after tax clearance is obtained from the Israel Tax Authority, the net proceeds are wired directly to the shareholders' foreign bank account. The shareholder never needs to open or maintain an Israeli bank account. This approach is used routinely for foreign shareholders worldwide - it is well-established legal practice in Israel.
The Israeli tax treatment of non-resident shareholders is generally favorable - but it requires proper documentation and certification. The home-country tax implications are separate and require coordination with the shareholder's foreign tax advisors.
Non-resident shareholders are generally exempt from Israeli capital gains tax on the sale of shares of Israeli public companies traded on the Tel Aviv Stock Exchange - subject to qualifying conditions under Israeli tax law.
The exemption applies when the gain is not attributable to an Israeli permanent establishment, the shareholder qualifies as a non-resident under Israeli tax law, and the shares are not attributable to Israeli real estate rights. Each case requires individual assessment.
Before sale proceeds can be released to a foreign account, the Israel Tax Authority issues a certificate confirming the non-resident status and applicable exemption. We obtain this certificate as part of the engagement.
For U.S. taxpayers, the sale must be reported on the U.S. tax return regardless of the Israeli exemption. We provide documentation suitable for IRS Form 8938, FBAR (FinCEN 114), and Schedule D - and coordinate with the client's U.S. accountant.
UK residents may have HMRC reporting obligations on capital gains; Canadian residents have CRA reporting requirements; other jurisdictions have their own rules. We provide the documentation needed for foreign reporting, in coordination with local advisors.
Where shares originated from an employer stock-option plan or restricted stock unit grant, Section 102 of the Income Tax Ordinance applies - with specific rules on the holding period, beneficial tax treatment, and trustee involvement. Requires specialized handling.
We are not a large firm - and that is the point. Each matter is handled personally by the founding attorney, with direct attorney access throughout. For cross-border securities transactions where every step matters, this continuity is the value.
Adv. Reut Eliyahu handles each securities matter personally - from first consultation through funds received. No transfers to junior staff. You always know who is handling your case.
Adv. Eliyahu is a licensed Israeli notary. Notarial documentation can be issued in-house - saving time and coordination on cross-border documents that require notarial certification.
Working procedures already in place with the major Israeli trustees - Resnick Paz Nevo, IBI Trust, Mizrahi Tefahot Trust, and others. This streamlines liaison and reduces friction at every step.
Cross-border securities and corporate matters are a core practice area for our firm - not a peripheral service. Each engagement draws on direct prior experience with similar transactions, with deep familiarity in the Israeli trustee system, TASE procedures, and the Israeli Tax Authority practice.
Direct WhatsApp, email, and phone access. No call-center buffers. Foreign shareholders coordinating across time zones value this directly - questions get answered in hours, not days.
Every step of the process is handled remotely. No travel to Israel required. Foreign shareholders in the US, UK, Canada, France, Australia, and worldwide complete engagements without leaving their home country.
Free initial consultation. No obligation. Custom fee structure based on the specifics of your matter. Available by email, phone, or Zoom - at your convenience across time zones.
Founding Attorney & Notary · Eliyahu & Co. Law Office
Adv. Reut Eliyahu founded Eliyahu & Co. as a firm specializing in cross-border legal services for non-resident clients - with a particular focus on Israeli securities transactions, cross-border real estate, and Israeli corporate matters for foreign shareholders. A member of the Israel Bar Association since 2007 (License No. 47439), with 19+ years in practice, she holds LL.B and MBA degrees and is a registered notary and arbitrator.
The firm's securities practice covers the full process for foreign shareholders disposing of Israeli holdings - public company shares (TASE-listed and dual-listed), private company shareholdings, trustee-held securities at Israeli trust companies (Resnick Paz Nevo, IBI Trust, Mizrahi Tefahot Trust, Leumi Trust, Hapoalim Trust, Discount Trust), Israeli bonds and debentures, mutual fund units, and the specialized handling required for shares of real estate holding companies ("Chevrot Gush Chelka"). The work operates within the framework of the Israeli Income Tax Ordinance (with particular attention to Section 97A for non-resident exemption and Section 102 for employer-grant shares), the Companies Law, 5759-1999, and the regulations of the Israel Securities Authority.
Reut handles each securities matter personally - from first consultation through funds received in the shareholder's foreign account. Foreign shareholders coordinating across time zones particularly value this continuity: a single, reliable point of contact who knows the case in detail. Beyond securities, the firm's full practice covers Israeli inheritance and succession law, corporate and business law, foreign legal opinions on Israeli law, and notarial and apostille services - all of which frequently intersect with cross-border securities matters.
The firm is based in Herzliya Pituach and serves foreign shareholders from across the diaspora - the United States, Canada, the United Kingdom, France, Australia, and worldwide. Most engagements arrive by direct referral from previous foreign clients.
📍 The first consultation is free and without obligation.
Answers to the most common questions we receive from foreign shareholders considering the sale of Israeli securities - and from the family members helping them.
Tell us briefly about the Israeli shares you wish to sell - where they are held, the tax residency of the shareholders, and any documentation you have. We will get back to you within one business day. The first consultation is free and without obligation.
You can also read more about Israeli inheritance law, corporate and business law, foreign legal opinion on Israeli law, and notary and apostille services.
4 HaOgen Street, Herzliya Pituach, Israel
Sun - Thu: 08:00 - 19:00
Fri: 08:00 - 13:00
(Israel Time)
English · Hebrew
Free first consultation — no obligation, no fee.
We'll review your holdings, coordinate with the Israeli trustee, and handle the entire process remotely — including for shareholders without an Israeli bank account.