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Tourism Minister Stas Misezhnikov and his wife received free VIP tickets to the Madonna concert last September, Haaretz has learned, despite clear instructions from the attorney general that free tickets are considered an illegal gift.

The ministry said Misezhnikov was there as part of his ministerial duties.

The director of Misezhnikov's office, Limor Barzilai, and spokesman Amnon Lieberman, received tickets without seats, and senior ministry official Uzi Gafni had two regular tickets upgraded to VIP status for free. VIP tickets to the concert sold for NIS 2,500 each.

In late November, concert producer Shuki Weiss sent a letter to the ministry, noting that he gave the officials 25 tickets, most of them VIP tickets. Last week Haaretz asked the ministry why it had received so many expensive tickets. Two days later, Weiss sent a letter to Barzilai confirming five tickets, plus one for a bodyguard, had been delivered.

What happened to the other 20 tickets? Weiss declined to tell Haaretz how many tickets the ministry received. The ministry said it received only six tickets, two of which were upgraded, and that it paid full price for the bodyguard's VIP ticket.

By accepting the tickets, Misezhnikov appears to have violated the Gifts Law, which prohibits public servants, including elected and appointed officials, from accepting gifts. Gifts are defined as "an asset, a service or other benefits granted without compensation."

In 2005, Attorney General Menachem Mazuz responded to the practice of officials receiving free tickets to soccer games by stating that this falls into the category of illegal gifts.

However, Mazuz added that free tickets do not violate the gifts law if they are for a state or official public event, a charity event, or a public event with special significance and the ticket recipient is a guest of honor.

Generally speaking, Mazuz wrote, "Such events do not include regular occasions, like games and cultural events, which do not justify inviting the officials as guests of honor."

Responsibility for not violating the law rests primarily "with the official," he said. "Therefore, if there is any doubt about the circumstances of the invitation, the public servant must consult his ministry's legal adviser and act in keeping with his instructions."

Tourism Ministry spokeswoman Shira Koa said that the ministry had agreed with the producers of the concert that the event would be used to promote Israel as a safe tourism destination. "Madonna belongs to an exclusive club of mega stars, who draws thousands of fans from abroad to her concerts," the statement said.

"For this reason, the ministry authorized an agreement with the producers that would give the ministry video and stills footage of the singer and her entourage, both during the concerts and her visits to tourist sites in Israel, to be used in international marketing campaigns. They also agreed to have four displays at the concert with films promoting Israel, supplied by the ministry, targeting the thousands of foreign tourists. The ministry agreed to pay NIS 56,000, not including tax, for this agreement.

"Such promotion campaigns are regular occurances both in Israel and abroad," it stated.

"The team that worked on the project - the minister's media adviser Amnon Lieberman, and project manager Limor Barzilai, attended the concert with the ministry's permission, as part of their work. The ministry official responsible for the project, Uzi Gafni, who had purchased two tickets for the concert, had them upgraded, with the ministry's permission, to VIP tickets."

"The minister and his spouse, having obtained ministry confirmation, was also present at the concert. A separate ticket was purchased by the ministry for the minister's bodyguard."

Concert producer Shuki Weiss declined to comment.