Revisiting Business Restructuring in Light of Israeli Court Decisions and Circulars

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. Since then, however, an Israeli tax court has reached a legal decision that changes the landscape and this article will therefore revisit certain transfer pricing aspects of business restructuring in Israel.