Logo

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

Media Centre

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

7 March 2019

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.

Search by +