Both cases mentioned above will be subject to the provisions of Article 4-B of the Income Tax Law.

• Income obtained through foreign entities that carry out business activities, unless their passive income represents more than 20% of their total income.

• The taxpayer must obtain authorization to exclude passive income generated by a foreign entity that is authorized to act as a financing entity by the authorities of the country in which they reside.

• When shares are sold within the same group, resulting from an international restructuring, provided they meet various requirements, including filing a notice with the tax authority prior to the restructuring.