Redefining residency: Israel’s proposals and lessons from the UK

The Israel Tax Authority published a draft bill on 2 July 2025 regarding how to determine an individual’s place of residence for tax purposes. The bill focuses foremost on counting days of presence in Israel and establishing conclusive presumptions that override the current ‘centre of life’ test.

The ‘centre of life’ test considers factors such as the residency of the taxpayer’s family the location of their permanent home their place of work as well as other social and economic links. While these links can often be subjective they are important indicators to consider to establish tax residency.

This draft bill follows on from the published conclusions in November 2024 from a committee for reform in international taxation chaired by the then deputy director for professional matters Roland Am-Shalem CPA (also a jurist). In relation to tax residency the committee established the following...