Number 6 - 2006 contains the following:
 

The purpose of this article is twofold: to trace the derivation of the terms used in the OECD Model (including, as terms for this purpose, the categories of income and their definition) to their original state or states, and the converse -- the extent to which the Model has influenced the internal law of states. The former may shed some light on the meaning of civil law expressions unfamiliar to common law readers and, to a far smaller extent, on the meaning of common law expressions unfamiliar to civil law readers. The article does not make any claim to be comprehensive as the source of many of the expressions may be lost in the mists of history or may have originated in states not represented by the authors. The authors' impression is that the Model has had less influence on internal law than might have been expected, perhaps so that states retain their treaty negotiating position. In conclusion, the authors have found virtually no concept in any of the Models that cannot be found in an earlier treaty. The Models have in turn influenced later treaties.

Israel recently adopted severe legislative measures against the "aggressive tax planning" used by taxpayers, especially following the transition from the "territorial" to the "personal" basis for imposing the income tax. The term "aggressive tax planning" has not been statutorily defined, but a commission appointed for dealing with aggressive tax planning has pointed out many of the characteristics that are common to it. To enable the Israeli Revenue to have more information about the tax planning techniques used by taxpayers, the legislature enacted detailed rules imposing the legal obligation to disclose information that will enable the Revenue to counteract any tax planning which it considers to be "illegitimate" tax avoidance. This article examines the new rules prescribing the information that taxpayers are now required to give. The article also surveys the general attitude of the Israeli courts towards tax avoidance.