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Israeli court favors Tax Authority's position on deemed sale of IP

29 June 2023

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Tax Alerts, National/Federal Taxation, H...

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Israel

An Israeli district court ruled in favor of the Israeli Tax Authority (ITA), which claimed that Medtronic Ventor Technologies Ltd. (Medtronic Israel) sold its intellectual property (IP) to Medtronic Inc. and other group companies (the Group) shortly after its acquisition.The court's ruling was based in part on the (i) retroactive effect of research and development services and license agreements signed between Medtronic Israel and Group companies, (ii) transfer of legal rights to some of Medtronic Israel's patents to the Group, and (iii) location of Medtronic Israel's strategic management after acquisition.Israeli companies and multinational enterprises that acquire Israeli companies should be...