Exhibit 8.1
C. Organizational Structure
The following table sets forth the legal name, location and country or state of incorporation and percentage ownership of our subsidiaries as of December 31, 2024:
| Country of | Ownership | |||
| Subsidiaries and affiliate | Incorporation | Percentage | ||
| 9540 Y.G. Soft I.T Ltd. (shares held by CommIT Software Ltd.) | Israel | 60% | ||
| Allstates Consulting Services LLC (shares held by Magic Software Enterprises Inc.) | Delaware | 100% | ||
| AI Team Software Solutions Ltd (shares held by CommIT AI Ltd) | Israel | 85% | ||
| AppBuilder Solutions Ltd | United Kingdom | 100% | ||
| Appush Technologies Ltd (Formerly known as Vidstart Ltd) | Israel | 100% | ||
| Appush Inc. (Shares held by Appush Technologies Ltd) | Delaware | 100% | ||
| Aptonet, Inc. (shares held by Coretech Consulting Group LLC) | Georgia | 100% | ||
| Autonomy AI Technologies Inc (shares held by Sanjer AI Ltd) | Israel | 100% | ||
| B.A Microwaves Ltd. (shares held by CommIT Embedded Ltd.) | Israel | 69.38% | ||
| BridgeQuest Labs, Inc. (shares held by BridgeQuest, Inc.) | North Carolina | 100% | ||
| BridgeQuest, Inc. (shares held by Magic Software Enterprises Inc.) | North Carolina | 100% | ||
| Comblack IT Ltd | Israel | 80.24% | ||
| Comblack Municipal Services Ltd. (shares held by Comblack IT Ltd.) | Israel | 70% | ||
| CommIT AI Ltd (shares held by Comm-IT Technology Solutions Ltd.) | Israel | 100% | ||
| CommIT Technology Solutions Ltd | Israel | 76.07% | ||
| Comm-IT Technology Canada Inc. (shares held by Comm-IT Technology Solutions Ltd.) | Canada | 100% | ||
| Comm-IT Technology UK Ltd (shares held by Comm-IT Technology Solutions Ltd.) | United Kingdom | 100% | ||
| CommIT Software Ltd (shares held by Comm-IT Technology Solutions Ltd.) | Israel | 100% | ||
| CommIT Embedded Ltd (shares held by Comm-IT Technology Solutions Ltd.) | Israel | 75% | ||
| Comm-IT USA, Inc. (shares held by Comm-IT Technology Solutions Ltd.) | Delaware | 100% | ||
| Complete Business Solutions Ltd | Israel | 100% | ||
| Coretech Consulting Group Inc (shares held by Magic Software Enterprises Inc) | Pennsylvania | 100% | ||
| Coretech Consulting Group LLC (shares held by Magic Software Enterprises Inc) | Delaware | 100% | ||
| Dario Solutions IT Ltd (shares held by Comm-IT Technology Solutions Ltd.) | Israel | 100% | ||
| Datamind Technologies Ltd (shares held by Complete Business Solutions Ltd) | Israel | 90.1% | ||
| Enable IT Consulting Services Canada Inc. (shares held by Enable IT LLC.) | Canada | 100% | ||
| Enable IT LLC. (shares held by Coretech Consulting Group LLC) | Delaware | 100% | ||
| Executive Life, Ltd (shares held by Coretech Consulting Group LLC) | New York | 100% | ||
| F.T.S. - Formula Telecom Solutions Ltd | Israel | 100% | ||
| Fusion Solutions LLC. (shares held by Coretech Consulting Group LLC) | Delaware | 100% | ||
| Fusion Technical Solutions LLC. (shares held by Fusion Solutions LLC) | Delaware | 49% | ||
| Futurewave Systems, Inc. (shares held by Fusion Solutions LLC.) | Georgia | 100% | ||
| The Goodkind Group LLC (shares held by Coretech Consulting Group LLC) | New York | 100% | ||
| Goodkind Hospitality, LLC (shares held by The Goodkind Group LLC) | Delaware | 100% | ||
| Goodkind Services Group, LLC (shares held by Goodkind Hospitality, LLC) | New York | 100% | ||
| Hermes Logistics Technologies Limited (shares held by Magic Software Enterprises (UK) Ltd) | United Kingdom | 100% | ||
| Infinigy (UK) Holdings Limited | United Kingdom | 100% | ||
| Infinigy (US) Holding Inc (shares held by Infinigy (UK) Holdings Limited) | Georgia | 100% | ||
| Infinigy Engineering LLP (shares held by Infinigy Solutions LLC.). | Georgia | 100% | ||
| Infinigy Solutions LLC. (shares held by Infinigy (US) Holding Inc) | Georgia | 100% | ||
| Intrabases SAS (shares held by Magic Software Enterprises France) | France | 100% |
| Country of | Ownership | |||
| Subsidiaries and affiliate | Incorporation | Percentage | ||
| K.M.T. (M.H.) Technologies Communication Computer Ltd. | Israel | 60% | ||
| Knowledge & Solutions Software B.V. (shares held by Benelux B.V.) | Netherlands | 100% | ||
| Magic Beheer B.V. (shares held by Magic Software Enterprises Netherlands B.V.) | Netherlands | 100% | ||
| Magic Benelux B.V. (shares held by Magic Beheer B.V.) | Netherlands | 100% | ||
| Magic Hands B.V. (shares held by Benelux B.V.) | Netherlands | 100% | ||
| Magic Software Enterprises (Israel) Ltd | Israel | 100% | ||
| Magic Software Enterprises (UK) Ltd (shares held by Magic Software Enterprises Netherlands B.V.) | United Kingdom | 100% | ||
| Magic Software Enterprises France (shares held by Magic Software Enterprises Netherlands B.V.) | France | 100% | ||
| Magic Software Enterprises GMBH (shares held by Magic Software Enterprises Netherlands B.V.) | Germany | 100% | ||
| Magic Software Enterprises Inc. | Delaware | 100% | ||
| Magic Software Enterprises India Pvt. Ltd | India | 100% | ||
| Magic Software Enterprises Netherlands B.V. | Netherlands | 100% | ||
| Magic Software Enterprises Spain Ltd (shares held by Magic Software Enterprises Netherlands B.V.) | Spain | 100% | ||
| Magic Software Japan K.K | Japan | 100% | ||
| Magix Integration (Proprietary) Ltd | South Africa | 100% | ||
| Menarva Ltd. | Israel | 100% | ||
| Minereye Technologies Ltd (shares held by CommIT Technology Solutions Ltd) | Israel | 55% | ||
| Mobisoft Ltd. | Israel | 98.52% | ||
| NetEffects, Inc. (shares held by Coretech Consulting Group LLC) | Missouri | 100% | ||
| OnTarget Group, Inc | North Carolina | 100% | ||
| OnTarget Labs Inc (shares held by OnTarget Group, Inc) | Russia | 100% | ||
| OnTarget Labs Latvia (shares held by OnTarget Group, Inc) | Latvia | 100% | ||
| OnTarget Labs LLC Russia (shares held by OnTarget Group, Inc) | Russia | 100% | ||
| Magic Quest Labs LLC (shares held by OnTarget Labs, Inc.) | Georgia | 100% | ||
| Onyx Magyarorszag Szsoftverhaz (shares held by Magic Software Enterprises Netherlands B.V.) | Hungary | 100% | ||
| Pilat (North America), Inc. | New Jersey | 100% | ||
| Pilat Europe Ltd. | United Kingdom | 100% | ||
| PowWow Inc. (shares held by Magic Software Enterprises Inc.) | California | 100% | ||
| Quickode Ltd (shares held by CommIT Software Ltd.) | Israel | 100% | ||
| Roshtov Software Industries Ltd | Israel | 80.05% | ||
| Sanjer AI Ltd. (shares held by CommIT Software Ltd.) | Israel | 26% | ||
| Shavit Software (2009) Ltd. (shares held by Comblack Ltd) | Israel | 100% | ||
| Skysoft Solutions Ltd. (shares held by CommIT Embedded Ltd.) | Israel | 75% | ||
| Stockell Information Systems Inc )shares held by Coretech Consulting Group LLC) | Missouri | 100% | ||
| Theoris, Inc (shares held by Coretech Consulting Group LLC) | Indiana | 100% | ||
| Twingo Ltd (shares held by Comm-IT Technology Solutions Ltd.) | Israel | 60% | ||
| Valinor Ltd. (shares held by Comm-IT Technology Solutions Ltd.) | Israel | 100% | ||
| Xsell Resources Inc. (shares held by Coretech Consulting Group LLC) | Pennsylvania | 100% |