Real estate taxation · Position Paper
Real Estate Taxation Professional Position Paper No. 06/26, Israel Tax Authority. Re: Application of Section 19(3a) of the Real Estate Taxation Law to Transactions in which the Purchaser Assumes a Tax Liability Imposed by Law on the Seller
Summary
Professional Position Paper 06/26 of the Israel Tax Authority addresses section 19(3a) of the Real Estate Taxation Law, under which, in the sale of a right that is conditional upon a future condition of increased utilisation possibilities under a plan, where the consideration was affected by this and is not wholly in money, the "date of sale" is the date on which the plan is approved. The Authority's position is that the section also applies to "net transactions", in which rights are sold in consideration for construction services and the purchaser assumes tax liabilities imposed on the seller, such as betterment tax, levies or fees to local authorities, and therefore the date of sale will be the date on which the plan is approved. The date of sale determines the deadline for the declaration under section 73 (30 days) and for payment under section 90A (60 days), and in other cases not mentioned, the professional department of the Real Estate Taxation Division should be consulted.
The summary was written by the office and reflects the instruction as of its publication date. The binding text is the official Hebrew publication, and the instruction may have been updated or affected by later legislation and case law. The English title and summary are an unofficial translation.
Publication details
- Type
- Position Paper
- Number
- 06/26
- Publication date
- 26.7.2026
- Topics
- Reporting and procedures, Betterment tax
- Sections of the Law mentioned
- 3 19
Official document
Source: The publication on the Israel Tax Authority website (gov.il, Hebrew)
Suggested citation
Israel Tax Authority, Position Paper 06/26, "Real Estate Taxation Professional Position Paper No. 06/26, Israel Tax Authority. Re: Application of Section 19(3a) of the Real Estate Taxation Law to Transactions in which the Purchaser Assumes a Tax Liability Imposed by Law on the Seller" (26.7.2026) [Hebrew]
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