EFTA Document EFTA01383715

II. Definition of Resident of Israel for Israeli Tax Purposes The following is an excerpt of Section 1 of the Israeli Income Tax Ordinance [New Version), 1961. as amended. which defines a "resident of Israel" or a "resident" as follows: "(A) with respect to an individual —a person whose center of vital interests is in Israel; for this purpose the following provisions will apply: (1) in order to determine the center of vital interests of an individual, account will be taken of the individual's family. economic and social connections. including, among others: (a) place of permanent home: (b) place of residential dwelling of the individual and the individual's immediate family; (c) place of the individual's regular or permanent occupation or the place of his permanent employment: (d) place of the individual's active and substantial economic interests: (e) place of the individual's activities in organizations, associations and other institutions; (2) the center of vital interests of an individual will be preswned to be in Israel: (a) if the individual was present in Israel for 183 days or more in the tax year. (b) if the individual was present in Israel for 30 days or more in the tax year, and the total period of the i ixiis idual's presence in Israel that tax year and the two previous tax years is 425 days or more. For the purposes of this provision, "day' includes a part of a day; (3) the presumption in subparagraph (2) may be rebutted either by the individual or by the assessing officer. (4) (B) with respect to a body of persons — a body of persons which meets one of the following: (I) it was incorporated in Israel: (2) the "control and management" of its business is exercised in Israel. excluding a body of persons the control and management of whose business is exercised in Israel by an individual that has become a resident of Israel for the first time or that has become a Veteran Returning Resident. as provided in Section 14(A). and ten years have not yet lapsed from the date on which he became an Israeli resident as aforesaid, or by anyone on his behalf, provided that such body or persons would not be a resident of Israel even if the control and management of its business had not been executed by such individual or anyone on his behalf. unless requested otherwise by the body of persons." The above is an unofficial English translation of the Ordinance in the Hebrew language, and is provided for convenience purposes only. Please consult your own tax advisors to determine the applicability of these definitions to you. CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0083510 CONFIDENTIAL SONY GM_00229694 EFTA01383715