A precise definition of business services was recently at the core of a dispute between the Israel Tax Authority and eBay Marketplace Israel Ltd., a subsidiary of the multinational eBay Group. The district court litigated...more
A draft bill to amend the Income Tax Ordinance was published in early March 2024. The objective of the draft bill is to increase transparency in the Israeli tax system. That is in order to combat unreported capital and to...more
At the beginning of November 2023, the Israel Tax Authority published special instructions granting concessions to employees issued a company car who were subsequently called up for emergency reserve duty under an Order 8 or...more
A district court ruling handed down this past September addresses the legitimacy of distributing dividends prior to a sale of shares in order to reduce the tax liability deriving from the transaction. The court found that, in...more
The Israel Tax Authority’s May 2023 guidelines state that, under particular circumstances, investments via SAFEs (simple agreement for future equity) will be considered an advance on a share investment account. That being the...more
Generally speaking, a corporation inversion is a process of changing the holding structure of an existing company by transferring all of the existing company’s issued share capital from its shareholders to a new company, in...more
The district court recently ruled that when determining a business’s correct reporting method to the Israel Tax Authority (ITA)—on an accrual or a cash basis—it is insufficient to examine the technical question of a...more
The uptrend in the number of public shell acquisitions has prompted the Israel Tax Authority to be even more meticulous in its examination of such transactions. The Jerusalem District Court recently ruled that when a buyer...more
Does the sale price of intellectual property between related parties reflect its market value? The Tel Aviv District Court deliberated this question in October 2022. The ruling it handed down, which concurs with a series of...more
In May 2022, the Tel Aviv District Court issued an important ruling in the Medingo Ltd case on the tax aspects of business restructuring. This ruling joins a series of previous rulings, in the Gteko case and the Broadcom...more
6/27/2022
/ Acquisitions ,
Business Model ,
Corporate Restructuring ,
Corporate Taxes ,
Intellectual Property Protection ,
Intercompany Transactions ,
License Agreements ,
OECD ,
Related Parties ,
Research and Development ,
Share Purchase Agreements ,
Tax Authority
Hedge funds are generally entities that are managed by investment managers, in accordance with certain investment strategies, in order to invest in financial assets and generate returns for the hedge funds’ investors....more