Tag: Israel
Israel – Guidance on Limited Risk Distribution – Circular 12/2018
Circular on transfer pricing – profitability rates and ranges for certain transactions – Limited Risk Distributors (LRDs) ...
Israel – Guidance on Limited Risk Distribution – Circular 11/2018
Circular on transfer pricing – profitability rates and ranges for certain transactions – Limited Risk Distributors (LRDs) ...
Israel vs Hewlett-Packard, July 2017, Settled in International Arbitration
Hewlett-Packard pays NIS 1.6 billion ($450 million) in tax on its 2006 acquisition of the intellectual property of Israel company Mercury Interactive, in addition to the NIS 1 billion already paid to the Israel Tax Authority. The acquisition at issue took place in two stages. First the shares in Mercury Interactive were acquired by Hewlett-Packard for $4.5 billion in 2006. Then in 2009 Mercury Interactive’s intellectual property was transferred to Hewlett-Packard for a substantially lower price of $963 million. The Tax Authority held that the sales of the intellectual property should be taxed at the full value of $4.5 billion The case was settled in international arbitration, which ended with an additional tax payment of NIS 1.6 billion by Hewlett-Packard ...