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Corporate Tax

17 January 2020
Anat Shavit Tax implications of sale of functions, assets and risks to affiliates

Israel - Fischer Behar Chen Well Orion & Co

In a recent decision, a district court in Israel ruled in favour of Broadcom Semiconductor Ltd and rejected the Israeli Tax Authority's claim that Broadcom Semiconductor was required to pay additional taxes of NIS100 million due to the deemed sale of its main functions and assets to affiliated companies. In its decision, the court ruled that a change of a company's business model would not necessarily be deemed as a sale of its assets (and, in particular, a sale of its intellectual property).

Authors: Anat Shavit, Jonathan Shtang
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