"[...] The broad net of the Tax Appeal Law applies to businesses, individuals, activities, and various entities - small and large - in a company. Against this background, even if the interpretive scales were hostile, which is not the case, it is difficult to understand from a policy perspective why the transfer of a professional sports player from abroad to Israel would be an exception. In this context, it is said that Sport is a game, Spectator sport is entertainment, Professional sport is business, and usually - big business. We are dealing with a business and even a complex and economic business, in which a lot of money is involved in its management in Israel and abroad. Admittedly, the appellants are classified as non-profit organizations, and it appears that this is the property of many groups, but this status in itself does not exempt them from the obligation to appeal taxes when it comes to the import of goods. And again, we emphasize - in many ways, professional sports is a business in every way.(See Sports Connection, paragraph 22 of Justice Hendel's judgment).
- These words of Justice Hendel are undoubtedly true, and in my opinion there is no rabbi in them. This is because Section 1 of the Tax Appeal Law defines "goods" as including "right, benefit and other intangible assets"; and a "player card", which can be transferred, for money, from one professional football team to another, is nothing but a bundle of rights as defined in the regulations of the Israeli Football Association, the European Football Association (UEFA) and the World Football Association (FIFA). Regulations that are governed by contract law. In the context of all of this, Justice Hendel noted, contrary to what was quoted before us by the state, that professional soccer is not like a regular business such as a grocery store, a moving company or a law firm.
The Judge Handel Believe - As I also believe - Because for a business called professional sports there are Unique features of its own, which tax officials and tax judges must take into account when applying tax laws to teams and players.