The examiner's read, first
Your record reconstructed as an authority would reconstruct it — the only honest measure of what the position can withstand.
Tax residency & centre-of-life exposure
Residence is decided by facts. Make sure yours agree with each other.
Centre-of-life exposure counsel from Aun & Co.: the factual record behind tax-residency positions reviewed, aligned and documented before it is examined.
Tax residency disputes are fact disputes: where the permanent home stands, where the family lives, where the economic interests concentrate, how the presence days count. Israel's centre-of-life doctrine — like its counterparts abroad — reads the whole pattern, and authorities reconstruct it from records the taxpayer created without thinking: leases, schools, boards, bank flows, flights. The firm works on that factual layer with a litigator's discipline: assessing what the record currently proves, aligning it with the position claimed, and preparing the file for the examination that international lives eventually attract.
The work spans
- Exposure assessment: what your current record would prove if examined
- Fact-pattern alignment: closing gaps between position and paper
- The contemporaneous file: evidence built as life happens
- Dispute support in residency examinations and challenges
- Coordination with tax advisers on the strategy the facts must serve
- Your life spans countries and your residency position rests on facts nobody has audited.
- Presence days, family location and business ties have drifted from the position on file.
- An authority has opened questions about where your centre of life actually sits.
- You are structuring a move and want the factual record designed before it accumulates by accident.
The firm runs the examiner's exercise before the examiner does: your position reconstructed purely from the objective record — property, family, presence, economic ties — and compared with the position filed. Divergences are the exposure; each is closed by changing the facts, changing the documentation, or, where neither is honest, changing the position. When examination comes, the same discipline runs in reverse: the record marshalled, the pattern argued, the burden put where the law places it.
04 · What you get
Facts and filings aligned
Divergences between the life and the position closed deliberately, before they become the other side's exhibit list.
Litigation-grade file
Evidence assembled and preserved to dispute standard, because residency questions are ultimately decided the way cases are — on the record.
A typical engagement: an internationally mobile client's presence pattern has shifted over several years while the filed position stood still. The firm reconstructs what the record now shows, identifies the divergence, and works with the tax advisers to realign facts, documentation and position before any authority frames the question adversarially.
Described in abbreviated, anonymised form to preserve client confidentiality.
How is centre of life determined for Israeli tax residency?
By the whole factual pattern — permanent home, family location, economic and social ties, alongside statutory day-count presumptions. No single fact decides; the consistency of the pattern does, which is why contradictions within your own record are the principal exposure.
What records matter most in a residency examination?
The ones created without litigation in mind: leases and property use, school and community registrations, board roles, bank and card activity, travel logs. Authorities trust the record that accumulated naturally — building it deliberately, in real time, is the whole discipline.
What does a centre-of-life exposure review produce?
A written reconstruction of what your objective record currently proves, a gap analysis against your filed position, and an action plan — factual, documentary or positional — sequenced by risk. It is the audit you run on yourself before anyone else does.