Tel Aviv’s District Court ruled in favor of the Israeli Tax Authorities (ITA) who claimed that the intellectual property (IP) which CA Software Israel Ltd. sold back in 2010 was worth ILS667m (rather than ILS111m as claimed by the taxpayer).The Court’s ruling was based, inter-alia, on the failure of the taxpayer to provide supporting documentation from the time of the IP sale (i.e., real-time documentation).Israeli companies and multinational enterprises that acquire Israeli companies should be mindful of the sufficiency of documentation they have in support of any post-merger integration (PMI) and global IP structure rationalization.Executive summaryOn 25 October 2022, the...