The Israeli Ministry of Finance (MOF) has opened a public consultation (from 14 December 2025) on a draft memorandum of law that would introduce an R&D tax credit intended to remain effective under the OECD/G20 Inclusive Framework’s global minimum tax (Pillar Two / GloBE) rules.

Key features of the draft are as follows:

• The draft would grant an R&D tax credit (linked to domestic R&am…