New Israeli Tax Court Ruling on Post-Acquisition ‘Change of Business Model’
A new judgment in the case of Medtronic was recently issued by the Israeli District Court which accepted the ITA’s views and arguments. The latest court decision follows three District Court decisions from recent years on post-acquisition business restructuring and transfer pricing changes – Gteko, Broadcom and Medingo.
Acquirers of Israeli target companies should be aware of such rulings and should carefully consider the tax risks and exposures involved with entering into new intercompany transactions and amending transfer pricing post-acquisition.
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