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TAXES ON INCOME
 12 Months Ended
Dec. 31, 2023
Income Tax Disclosure [Abstract]  
TAXES ON INCOME
NOTE 19 -
TAXES ON INCOME
 
  a.
Tax benefits under the Law for the Encouragement of Capital Investments, 1959 ("the Law"):
 
Until December 31, 2010, TAT and Turbochrome has elected to participate in the alternative package of tax benefits for its approved and benefited enterprise under the law.
 
Pursuant to such Law, the income derived from those enterprises will be exempt from Israeli corporate tax for a specified benefit period (except to the extent that dividends are distributed during the tax-exemption period other than upon liquidation) and subject to reduced corporate tax rates for an additional period.
 
In addition pursuant to a recent amendment o f the Law, any distribution of dividend as of August 15, 2021 will be prorated between exempt income and taxable income. As such, upon dividend distribution, in case the company has accumulated exempt income, the company will be obligated to pay the corporate income tax it was exempted from with respect to the exempt profits portion.
 
Preferred Enterprises
 
Additional amendments to the Law became effective in January 2011 (the “2011 Amendment”). Under the 2011 Amendment, income derived by ‘Preferred Companies’ from ‘Preferred Enterprises’ (both as defined in the 2011 Amendment) would be subject to a uniform rate of corporate tax as opposed to the incentives that are limited to income from Approved or Benefiting Enterprises during their benefits period. According to the 2011 Amendment, the uniform tax rate on such income, referred to as ‘Preferred Income’, would be 6% in areas in Israel that are designated as Development Zone A and 12% elsewhere in Israel. Dividends distributed from taxable income derived from Preferred Enterprise would be subject to a 15% tax (or lower, if so provided under an applicable tax treaty), which would generally be withheld by the distributing Company .While the Company may incur additional tax liability in the event of distribution of dividends from tax exempt income generated from its Approved and Benefiting Enterprises, no additional tax liability will be incurred by the Company in the event of distribution of dividends from income taxed in accordance with the 2011 Amendment
 
Under the transitional provisions of the 2011 Amendment, the Company elected to irrevocably implement the 2011 Amendment, commencing 2011 and thereafter, and be regarded as a "Preferred Enterprise" with respect to its existing Approved and Benefited Enterprises while waiving benefits provided under the legislation prior to the 2011 Amendment.
 
  a.
Tax benefits under the Law for the Encouragement of Capital Investments, 1959 ("the Law") (cont.):
 
Under a recent amendment, announced in August 2013, beginning in 2014, dividends paid out of income attributed to a Preferred Enterprise will be subject to a withholding tax rate of 20% (instead of 15%). In addition, tax rates under the Preferred Enterprise were also raised effective as of January 1, 2014 to 9% in Zone A and 16%.
 
The uniform tax rate for Development Zone A, as of January 1, 2017, is 7.5% (as part of changes enacted in Amendment 73).
 
TAT is located in an area in Israel that is designated as elsewhere and as such entitled to reduce tax rates of 16%.
 
Turbochrome is in an area in Israel that is designated as Zone A and as such entitled to reduce tax rates of 7.5%.
 
  b.
Corporate tax rate in Israel
 
The taxable income of TAT, not subject to benefits as detailed above, is taxed at corporate tax rate, which was 23% for all years included in these financial statements.
 
Capital gain is subject to capital gain tax according to corporate tax rate in the year which the assets are sold.
 
As of December 31, 2023, the Company has an accumulated tax loss carryforward from Israeli subsidiary of approximately $2,927 million (as of December 31, 2022, $3,068 million). Such carry forward loss has no expiration date
 
  c.
U.S. subsidiaries
 
U.S. subsidiaries are taxed based on federal and state tax laws. The Federal statutory tax rate for 2023, 2022 and 2021 was 21% plus 3%-6% for state taxes.
 
As of December 31, 2023, the Company has an accumulated tax loss carryforward of approximately $138 (as of December 31, 2022, $970). Under U.S. tax laws, subject to certain limitations, carryforward tax losses originating in tax years beginning after January 1, 2018, have no expiration date, but are limited as a deduction to 80% of taxable income in any given year
 
  d.
Tax assessments
 
TAT’s income tax assessments are considered final through 2017.
 
   
Turbochrome income tax assessments are considered final through 2017.
 
   
Limco-Piedmont income tax assessments are considered final through 2018.
 
  e.
Income tax reconciliation:
 
A reconciliation of the theoretical tax expense assuming all income is taxed at the statutory rate to taxes on income (tax benefit) as reported in the statements of income:
 
   
Year ended December 31,
  
   
2023
    
2022
    
2021
  
Income (loss) before taxes on income (tax benefit) from continued operations reported in the statements of income
  
$
4,745
    
$
(1,648
)
  
$
(4,575
)
                         
Statutory tax rate in Israel
    
23
%
    
23
%
    
23
%
                         
Theoretical taxes on income (tax benefit)
    
1,091
    
$
(379
)
  
$
(1,052
)
                         
Increase (decrease) in taxes on income resulting from:
                        
Tax adjustment for foreign subsidiaries subject to a different tax rate
    
(36
)
    
(13
)
    
75
  
Reduced tax rate on income derived from "Preferred Enterprises" plans
    
(484
)
    
(48
)
    
149
  
Deferred tax assets from discontinued operation profit (loss)
            
-
      
98
  
Reduced deferred tax asset from expecting utilization of carryforward losses
    
183
      
-
      
-
  
Tax in respect of prior years
            
59
      
24
  
Temporary differences for which no deferred taxes were recorded
    
-
      
238
      
-
  
Permanent differences
    
-
      
77
      
71
  
Other adjustments
    
(178
)
    
164
      
(27
)
Taxes on income (tax benefit) as reported in the statements of income
  
$
576
    
$
98
    
$
(662
)
 
  f.
Income (loss) before taxes on income (tax benefit) is comprised as follows:
 
   
Year ended December 31,
  
   
2023
    
2022
    
2021
  
                   
Domestic (Israel)
  
$
4,639
    
$
(1,201
)
  
$
(5,139
)
Foreign (United States)
    
106
      
(447
)
    
564
  
                         
   
$
4,745
    
$
(1,648
)
  
$
(4,575
)
 
  g.
Taxes on income (tax benefit) included in the statements of income:
 
   
Year ended December 31,
  
   
2023
    
2022
    
2021
  
Current:
                  
Domestic (Israel)
  
$
-
    
$
-
    
$
-
  
Foreign (United States)
    
49
      
-
      
-
  
                         
     
49
      
-
      
-
  
Deferred:
                        
Domestic (Israel)
    
358
      
268
      
(579
)
Foreign (United States)
    
169
      
(111
)
    
(107
)
                         
     
576
      
157
      
(686
)
Previous years:
                        
Domestic (Israel)
    
-
      
-
      
-
  
Foreign (United States)
    
-
      
(59
)
    
24
  
                         
   
$
576
    
$
98
    
$
(662
)
 
  h.
Deferred income taxes:
 
Deferred income taxes reflect the net tax effects of temporary differences between the carrying amounts of assets and liabilities for financial reporting purposes and the amounts used for income tax purposes. Significant components of TAT's deferred tax liabilities and assets are as follows:
 
   
December 31,
  
   
2023
    
2022
  
Deferred tax assets:
            
Provisions for employee benefits
  
$
657
    
$
378
  
Inventory
    
1,337
      
1,288
  
Capital tax losses carryforward
    
956
      
2,475
  
                 
Net operating losses carryforward
    
2,368
      
4,040
  
R&D expenses
    
121
      
144
  
Other
    
417
      
331
  
Deferred tax assets, before valuation allowance
  
$
5,856
    
$
8,656
  
Valuation allowance
    
(3,214
)
    
(5,202
)
Deferred tax assets, net
    
2,642
    
$
3,454
  
                 
Deferred tax liabilities:
                
Property, plant and equipment
    
(1,348
)
    
(1,884
)
Intangible assets
    
(300
)
    
(341
)
                 
Other temporary differences deferred tax liabilities
            
-
  
Deferred tax liabilities
  
$
(1,648
)
  
$
(2,225
)
                 
Net
    
994
    
$
1,229
  
 
The following table summarizes the changes in the valuation allowance for deferred tax assets:
 
Balance, December 31, 2020
  
$
5,484
  
Deductions during the year
    
-
  
Balance, December 31,2021
  
$
5,484
  
Deductions during the year
    
(282
)
Balance, December 31,2022
  
$
5,202
  
Deductions during the year
    
(1,988
)
Balance, December 31,2023
    
3,214
  
 

Valuation allowances

 

Are mainly related to   (i) Capital losses attributed to the Company in the amount of $ 956. (ii) Corporate income  tax losses carryforward incurred in TAT Gedera in amount of $2,258.