Tax assessment litigation concerning tax incentives for a Philippine subsidiary
First written in FY2017-Q1. 7 of 11 entries say "Restated". Latest entry: FY2019-Q3.
No other company in this theme has enough history to compare yet.
- FY2019-Q3DroppedAnnual report
「Advanced World Systems, Inc., a consolidated subsidiary of the company, had been subject to an additional tax assessment by the Bureau of Internal Revenue of the Republic of the Philippines. After filing an action with the country’s Tax Court seeking cancellation of the assessment and a declaration that the tax audit was invalid, the court declared the tax audit invalid and the proceedings concluded on 10 October 2018, making the consolidated subsidiary’s victory final. Accordingly, the item “⑧ Tax-related risks: a. Litigation and other matters” included in the annual securities report for the previous fiscal year is no longer applicable.」
The subsidiary’s victory in the additional tax assessment litigation became final, and the tax litigation risk disclosed in the previous fiscal year ceased to apply. - FY2019-Q2MitigatedAnnual report
「On 10 October 2018, the Bureau of Internal Revenue’s motion for reconsideration was dismissed. The cancellation of the assessment, the invalidity of the tax audit and the conclusion of the proceedings were declared, and the consolidated subsidiary’s victory became final.」
In the litigation concerning the PHP 51.444 million additional tax assessment, the Bureau of Internal Revenue’s motion for reconsideration was dismissed, and the subsidiary’s victory and the conclusion of the proceedings became final. - FY2019-Q1RestatedAnnual report
「Following a tax audit, the consolidated subsidiary received a notice of assessment from the country’s Bureau of Internal Revenue dated 29 December 2014. The notice challenged the application of income tax incentives to the Makati branch of the consolidated subsidiary and imposed an additional tax assessment of PHP 51.444 million, including accrued interest. On 28 January 2015, the consolidated subsidiary filed an action with the country’s Tax Court seeking cancellation of the assessment and a declaration that the tax audit was invalid, on the grounds that the assessment contained material errors of fact and was unjustified. On 19 March 2018, a decision by a collegiate division was issued recognizing the consolidated subsidiary’s claims and declaring the tax audit invalid. The Bureau of Internal Revenue subsequently filed a motion with the full court seeking reconsideration of the decision.」
Continued disclosure that the Bureau of Internal Revenue filed a motion for reconsideration after the collegiate division’s decision. - FY2018MitigatedAnnual report
「Following a tax audit, the consolidated subsidiary received a notice of assessment from the country’s Bureau of Internal Revenue dated 29 December 2014. The notice challenged the application of income tax incentives to the Makati branch of the consolidated subsidiary and imposed an additional tax assessment of PHP 51.444 million, including accrued interest. On 28 January 2015, the consolidated subsidiary filed an action with the country’s Tax Court seeking cancellation of the assessment and a declaration that the tax audit was invalid, on the grounds that the assessment contained material errors of fact and was unjustified. On 19 March 2018, a decision by a collegiate division was issued recognizing the consolidated subsidiary’s claims and declaring the tax audit invalid. The Bureau of Internal Revenue subsequently filed a motion with the full court seeking reconsideration of the decision.」
While the collegiate division accepted the subsidiary’s claims and declared the tax audit invalid, the Bureau of Internal Revenue has filed a motion for reconsideration, and litigation risk remains. - FY2018-Q3RestatedAnnual report
「The notice states that the application of income tax incentives to the Makati branch of the consolidated subsidiary was challenged and that an additional tax assessment of PHP 51.444 million, including accrued interest, was imposed. On 28 January 2015, the consolidated subsidiary filed an action with the country’s Tax Court seeking cancellation of the assessment and a declaration that the tax audit was invalid, on the grounds that the assessment contained material errors of fact and was unjustified.」
The PHP 51.444 million additional tax assessment notice, the action filed with the Tax Court and the assessment that the probability of prevailing was high are reiterated. - FY2018-Q2RestatedAnnual report
「The notice states that the application of income tax incentives to the Makati branch of the consolidated subsidiary was challenged and that an additional tax assessment of PHP 51.444 million, including accrued interest, was imposed. On 28 January 2015, the consolidated subsidiary filed an action with the country’s Tax Court seeking cancellation of the assessment and a declaration that the tax audit was invalid, on the grounds that the assessment contained material errors of fact and was unjustified.」
The PHP 51.444 million additional tax assessment notice, the action filed with the Tax Court and the assessment that the probability of prevailing was high are reiterated. - FY2018-Q1RestatedAnnual report
「Following a tax audit, the consolidated subsidiary received a notice of assessment from the country’s Bureau of Internal Revenue dated 29 December 2014. The notice challenged the application of income tax incentives to the Makati branch of the consolidated subsidiary and imposed an additional tax assessment of PHP 51.444 million, including accrued interest. On 28 January 2015, the consolidated subsidiary filed an action with the country’s Tax Court seeking cancellation of the assessment and a declaration that the tax audit was invalid, on the grounds that the assessment contained material errors of fact and was unjustified.」
The PHP 51.444 million additional tax assessment notice, the action filed with the Tax Court and the assessment that the probability of prevailing was high are reiterated. - FY2017RestatedAnnual report
「On 28 January 2015, the consolidated subsidiary filed an action with the country’s Tax Court seeking cancellation of the assessment and a declaration that the tax audit was invalid, on the grounds that the assessment contained material errors of fact and was unjustified.」
The PHP 51.444 million additional tax assessment notice and the continuation of the proceedings before the Tax Court are reiterated. - FY2017-Q3RestatedAnnual report
「The notice states that the application of income tax incentives to the Makati branch of the consolidated subsidiary was challenged and that an additional tax assessment of PHP 51.444 million, including accrued interest, was imposed.」
There has been no material change in the PHP 51.444 million additional tax assessment notice issued to the Philippine subsidiary or the status of the proceedings. - FY2017-Q2RestatedAnnual report
「The notice states that the application of income tax incentives to the Makati branch of the consolidated subsidiary was challenged and that an additional tax assessment of PHP 51.444 million, including accrued interest, was imposed.」
There has been no material change in the additional tax assessment notice for the Philippine subsidiary, the PHP 51.444 million claim or the status of the proceedings before the Tax Court. - FY2017-Q1First statedAnnual report
「The notice states that the application of income tax incentives to the Makati branch of the consolidated subsidiary was challenged and that an additional tax assessment of PHP 51.444 million, including accrued interest, was imposed. On 28 January 2015, the consolidated subsidiary filed an action with the country’s Tax Court seeking cancellation of the assessment and a declaration that the tax audit was invalid, on the grounds that the assessment contained material errors of fact and was unjustified.」
An additional tax assessment notice was issued and an action was filed with the Tax Court. The company stated that, based on the opinions of its legal advisers and other information, it considered the probability of prevailing to be high.