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Mar 07, 2019

Client Update | Israeli District Court: In an IP/FAR Tax Case the Burden of Proof is on the Taxpayer

The Tel Aviv District Court recently delivered a decision in a tax appeal of Broadcom (Tax Appeal 17419-02-18), finding that the burden of proof is on the taxpayer regarding whether a transaction has to be treated as an intellectual property sale (as was reported by the taxpayer) or as a business restructuring in which the functions, assets and risks (“FAR”) of the taxpayer were sold (as was argued by the Israel Tax Authority). 

Click here for the full update.

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