Courts Again Side with Israeli Taxpayer in Transfer Pricing Business Restructuring Ruling

Abstract

In April 2019, the authors published in the International Transfer Pricing Journal an article that addressed, inter alia, OECD and Israeli principles of business restructuring, focusing on the various resulting models, such as outright sale and licensing structures. Subsequently, however, the authors published a revisit to this topic in October 2020 as an Israeli tax court reached a legal countering decision. The current article considers this detailed background as well as the most recent court developments in this regard in a May 2022 ruling.