Israel: how days are counted

At a glance

The test: Centre of life. It is presumed to be in Israel if the person was in Israel 183 days or more in the tax year, or 30 days or more in the year and 425 days or more in the year and the two before.
Period: The tax year, which is the calendar year.
What counts as a day: For the presumptions, a day includes part of a day.

The rule

The Income Tax Ordinance s.1 defines an Israeli resident as a person whose centre of life is in Israel. It lists factors to weigh: family, economic and social ties, including a permanent home, where the person and family live, where they usually work, active economic interests and organisations they take part in.

The Ordinance then sets two presumptions that the centre of life is in Israel. One is 183 days or more in the tax year. The other is 30 days or more in the tax year and 425 days or more in total across the tax year and the two years before.

Both the person and the assessing officer can rebut a presumption. A person can also meet the Ordinance's definition of a foreign resident, which needs at least 183 days outside Israel in each of two years and a centre of life outside Israel in the next two.

How Atrium counts it

Atrium counts a day in Israel when your recorded trips show you there at any point that day. Arrival and departure days both count. The year is the calendar year.

It shows the days left before whichever presumption is nearer: 183 days this year, or 30 days this year with 425 across three years. It uses years you stated for earlier years if you have no trips recorded for them.

Atrium shows the numbers only. It does not assess centre of life or any rebuttal, and its text says the presumptions can be rebutted. The statute defines part-of-day counting only for the presumptions, and the official sources do not mention airport transit, so Atrium counts any presence.

What catches people out

A person can be under both presumptions and still have a centre of life in Israel.
The 425-day presumption can apply with a year of only 30 days, when the two earlier years were long.
A day includes part of a day, so arrival and departure days count even for a few hours.
The presumptions can be rebutted by the person or by the assessing officer. A low count does not end the question.
A draft law published in 2025 would change the rules. As of 27 September 2026 Atrium found no sign it had passed.

Cases

Decided case

Amishvili v Assessing Officer Tel Aviv 4

Supreme Court of Israel, sitting as the civil appeals court · 2018 · CA 476/17 (Amit Amishvili Rafi v Assessing Officer Tel Aviv 4) Source

The appellant was an Israeli citizen, single, whose family lived in Israel. Between 2002 and 2009 he alternated between Israel and abroad and won money in poker tournaments abroad. He was in Israel 30 days in 2007. The court accepted the assessing officer's position that his centre of life in 2007 was in Israel, so his income earned abroad that year was taxable in Israel. The decision is reported through a law firm article; the judgment text was not opened.

A low day count in the year did not prevent the court from finding a centre of life in Israel.

Worked example

Worked example (illustrative): the 30-day and 425-day presumption

Noa, a made-up consultant, was in Israel 150 days in 2024 and 140 days in 2025, a total of 290. On 1 June 2026 she has 100 days in 2026. The 425-day presumption needs 135 days in 2026 (425 minus 290), so she has 35 days left. The 183-day presumption would need 83 more. Atrium shows the nearer one, 35 days left, and notes that a presumption can be rebutted.

The earlier two years set how many days this year the 425-day presumption needs.

Sources

Based on the sources above, last reviewed on 2026-10-04. Educational content, not tax advice. Atrium counts days; whether those days make you resident is for you and your adviser to decide.

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