Israel vs Medtronic Ventor Technologies Ltd, June 2023, District Court, Case No 31671-09-18

Category: Business Restructuring, Delineation - Substance over Form, Intangibles - Goodwill Know-how Patents, Non-Recognition and Recharacterisation, Series of Related Transactions, Valuation - DCF and CUT/CUPs | Tag: , , , , , , , , , , , ,
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In 2008 and 2009 the Medtronic group acquired the entire share capital of the Israeli company, Ventor Technologies Ltd, for a sum of $325 million.

Subsequent to the acquisition various inter-company agreements were entered into between Ventor Technologies Ltd and Medtronics, but no transfer of intangible assets was recognised by the Group for tax purposes.

The tax authorities found that all the intangibles previously owned by Ventor had been transferred to Medtronic and issued an assessment of additional taxable profits.

An appeal was filed by Medtronic Ventor Technologies Ltd.

Judgement of the District Court

The court dismissed the appeal and upheld the assessment issued by the tax authorities.

 

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Israel vs medtronic-ventor ORG





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