Executive summaryThe Israeli Jerusalem District Court (the Court) ruled, on 16 August 2021, in the case of Sephira & Offek Ltd and Israel Daniel Amram vs. Jerusalem 3 Assessing Officer on the reclassification of a transaction in which a New Immigrant1 sold, in a tax exempt transaction, its French-registered trademark (SEPHIRA) to its wholly-owned Israeli company (the Company), following which the Company amortized that trademark that was deducted against the royalty income received from a French-related company, for the use of the said trademark.In addition, while the Company recorded its income from research and development (R&D) services as Preferred Income entitled...