During those years, when Bar Refaeli was in a highly publicised relationship with the Hollywood actor Leonardo DiCaprio, she claimed she was resident in the US.
However, the Israel Tax Authority investigated the matter and claims she spent more than 180 days in each of those years in Israel, making her an resident and liable to pay tax.
In the civil case, the Lod District Court found in favour of the tax authority and ordered her to pay 8 million shekels (£1.8 million) in income tax, although Bar Refaeli is appealing to the High Court of Justice on the matter.
In the criminal case, Bar Refaeli’s mother Tzipi Levine Refaeli, herself a former international model, is also charged with conspiring with her daughter to conceal the money.
Under the plea bargain being negotiated, Tzipi Refaeli would plead guilty to the more serious charges of money laundering and tax evasion and receive an 18-month sentence, while Bar Refaeli would plead guilty to the lesser charge of tax evasion and receive only community service.
She would also drop her appeal to the High Court in the civil case and agree to pay the outstanding 8 million shekels in tax.
Any plea bargain agreement would ultimately be subject to the approval of the Israeli courts.
Some in the State Attorney’s office are reportedly opposed to any deal that would allow Bar Refaeli to avoid jail.