Clarification: In the case of Fridman Hashori, the Israeli Supreme Court ruled that the VAT due date for real estate transactions, including combination transactions, is governed by Sections 28 and 29 of the VAT Law. Section 28(a) of the Law sets out the VAT due date for real estate sales, while Section 28(b) of the Law deals with the provision of construction services. The exception set out in Section 29 of the Law applies to the rules set out in both sections.

The VAT due date for a combination transaction is divided into two parts:

• ‍The sale of the land (or part of it) to the contractor – Sections 29(a) and 29(1) of the Law will apply.
• ‍The provision of construction services by the contractor in a "partial sale" transaction or in the sale of the replacement apartments by him in a "full sale" transaction – Sections 28(b) or Section 28(a), respectively, in conjunction with Section 29(1) of the Law will apply.

From the above, we learn that, in general, the VAT due date for a combination transaction (of both types mentioned above) is the date on which the land subject to the transaction is transferred to the contractor. This is unless, prior to the delivery of the real estate, the construction works on it have been completed in a transaction to provide construction services (partial sale) or if the real estate has been registered in the name of the contractor in a 'full sale' transaction and provided that the contractor has not been given any consideration prior to the delivery of the real estate to him.