Transfer pricing tax assessments, refunds and the risk of reassessments for subsequent fiscal years
First written in FY2017-Q1. 9 of 21 entries say "Restated". Latest entry: FY2023.
1 other company's latest entry also says "Mitigated".
- FY2023MitigatedAnnual report
「Accordingly, during the current consolidated fiscal year, the Company recognized approximately ¥7.7 billion in refunded taxes as a refund of corporate and other income taxes, and recognized the related refund interest as refund interest on corporate and other taxes under non-operating income. In addition, after comprehensively considering that the reduced reassessment would result in the refund of a substantial portion of the additional taxes already paid, among other factors, the Company withdrew the action seeking revocation of the assessment.」
The Company recognized the approximately ¥7.7 billion refund relating to the transfer pricing tax assessment and withdrew the action seeking revocation of the assessment. - FY2023-Q3MitigatedAnnual report
「Accordingly, during the nine-month period ended 31 December of the current fiscal year, the Company recognized approximately ¥7.7 billion in refunded taxes as a refund of corporate and other income taxes, and recognized the related refund interest as other non-operating income. In addition, after comprehensively considering that the reduced reassessment would result in the refund of a substantial portion of the additional taxes already paid, among other factors, the Company withdrew the action seeking revocation of the assessment.」
The Company recognized the approximately ¥7.7 billion refund that had been indicated as expected through the previous quarter and disclosed the withdrawal of the action seeking revocation of the transfer pricing tax assessment. - FY2023-Q2MitigatedAnnual report
「Subsequently, in October 2022, the Company received from the Nagoya Regional Taxation Bureau a notice of reassessment of corporate taxes and other amounts, reducing the amounts under the relevant reassessment and related measures. The reduced reassessment will result in a refund of approximately ¥7.7 billion in corporate and local taxes and other amounts already paid. The Company plans to recognize the refund, together with the refund interest arising in connection with it, in the fiscal year ending March 2023 as factors increasing net income. In addition, after comprehensively considering that the reduced reassessment would result in the refund of a substantial portion of the additional taxes already paid, among other factors, the Company withdrew the action seeking revocation of the assessment.」
The Company received a notice of a reduced reassessment relating to the transfer pricing tax assessment, resulting in an expected refund of approximately ¥7.7 billion in taxes already paid. The refund and withdrawal of the action represent further progress in addressing the existing tax issue. - FY2023-Q1MitigatedAnnual report
「The Company had recognized estimated tax amounts for each consolidated fiscal year from the fiscal year ending March 2016 onward after receiving notification in June 2017 of a reassessment under the transfer pricing tax regime relating to transactions between the Polish subsidiary and the Company. Following the completion of the tax audit covering the fiscal year ending March 2016 onward, the estimated amounts previously recognized were reversed.」
The tax audit covering the fiscal year ending March 2016 onward was completed, and the estimated tax amounts recognized to date were reversed. Part of the Company's response for subsequent years relating to the transfer pricing tax assessment has progressed. - FY2022AdvancedAnnual report
「Following subsequent proceedings, the Tokyo High Court issued a judgment in March 2022 upholding the Tokyo District Court's first-instance judgment, which had largely upheld the Company's claims, and dismissing both the State's appeal and the Company's cross-appeal. After comprehensively considering that the Company's claims had largely been upheld, among other factors, the Company did not file either a final appeal or a petition for acceptance of a final appeal. The State also did not file either a final appeal or a petition for acceptance of a final appeal by the deadline, and the appellate judgment therefore became final.」
The appellate judgment concerning the transfer pricing tax assessment for the fiscal years ending March 2007 through March 2010 became final, and the Company recognized a refund of approximately ¥5.8 billion in taxes paid in prior years. As the Company continues to address a separate reassessment relating to the fiscal year ending March 2011 and thereafter, the overall theme was treated as progressing rather than completed. - FY2021AdvancedAnnual report
「Following subsequent proceedings, the Tokyo District Court issued a judgment on 26 November 2020 that largely upheld the Company's claims and revoked the reassessment and related measures in respect of approximately ¥5.8 billion in total corporate and local taxes and other amounts (the "first-instance judgment"). The State, dissatisfied with the first-instance judgment, filed an appeal with the Tokyo High Court on 9 December 2020. In response, the Company filed a cross-appeal on 23 December 2020 with respect to the part of the first-instance judgment in which the Company's claims were not upheld.」
Following the first-instance judgment allowing the revocation of approximately ¥5.8 billion of the transfer pricing tax assessment relating to transactions with the Polish subsidiary, the State filed an appeal and the Company filed a cross-appeal. - FY2021-Q3AdvancedAnnual report
「Following subsequent proceedings, the Tokyo District Court issued a judgment on 26 November 2020 that largely upheld the Company's claims and revoked the reassessment and related measures in respect of approximately ¥5.8 billion in total corporate and local taxes and other amounts (the "first-instance judgment"). The State, dissatisfied with the first-instance judgment, filed an appeal with the Tokyo High Court on 9 December 2020. In response, the Company filed a cross-appeal on 23 December 2020 with respect to the part of the first-instance judgment in which the Company's claims were not upheld.」
In the action seeking revocation of the reassessment relating to transactions with the Polish subsidiary for the fiscal years ending March 2007 through March 2010, the first-instance judgment was issued, allowing the revocation of approximately ¥5.8 billion of the assessment. The State subsequently appealed, and the Company also filed a cross-appeal. - FY2021-Q2RestatedAnnual report
「For consolidated fiscal years from the fiscal year ended March 2016 onward, based on the circumstances described above, the company has estimated the tax amounts that would apply if it were subject to similar taxation and reflected them in its quarterly consolidated financial statements.」
While continuing the action seeking revocation of the transfer pricing tax assessment, the Company has continued to reflect in its quarterly consolidated financial statements the estimated tax amount that would arise if similar taxation were imposed for the fiscal years ending March 2016 and thereafter. - FY2021-Q1RestatedAnnual report
「For consolidated fiscal years from the fiscal year ended March 2016 onward, based on the circumstances described above, the company has estimated the tax amounts that would apply if it were subject to similar taxation and reflected them in its quarterly consolidated financial statements.」
While continuing the action seeking revocation of the transfer pricing tax assessment, the Company has continued to reflect in its quarterly financial statements the estimated tax amount that would arise if similar taxation were imposed for the fiscal years ending March 2016 and thereafter. - FY2020-Q3AdvancedAnnual report
「However, because the refund of corporate and local taxes and other amounts was limited to approximately ¥400 million at this stage, the company believes the entire assessment should be revoked and filed an action with the Tokyo District Court on 25 December 2019 seeking cancellation of the reassessment.」
After the ruling partially revoked the assessment, the company progressed from planning measures to obtain a refund of the remaining amount to filing an action with the Tokyo District Court on 25 December 2019 seeking cancellation of the reassessment. - FY2020-Q1AdvancedAnnual report
「The company subsequently filed an administrative appeal with the Nagoya National Tax Tribunal and received a ruling on 5 July 2019 partially revoking the assessment. However, because the ruling only provides for a refund of approximately ¥400 million in corporate and local taxes and other amounts, the company will carefully review its contents and plans to take the necessary measures in accordance with the law to seek full revocation of the assessment.」
Regarding the reassessment dated 23 June 2017, the company received a ruling on 5 July 2019 partially revoking the assessment, resulting in an expected refund of approximately ¥400 million. It plans to take the necessary measures to seek full revocation. - FY2019-Q3RestatedAnnual report
「Although the company expects that reaching this conclusion will take some time, it received notice on 23 June 2017 of a reassessment for the fiscal years from the fiscal year ended March 2011 through the fiscal year ended March 2015. Accordingly, it reflected in its financial statements for the fiscal year ended March 2017 the ¥8.5 billion in additional taxes for those five years, together with estimated taxes for the fiscal years ended March 2016 and March 2017 on the assumption that similar taxation would apply. For fiscal years from the fiscal year ended March 2018 onward, estimated tax amounts have been reflected in the financial statements as necessary.」
While continuing the action seeking cancellation of the reassessment under the transfer pricing rules, the company continues to reflect estimated tax amounts for subsequent fiscal years in its financial statements as necessary. - FY2019-Q2RestatedAnnual report
「Although the company expects that reaching this conclusion will take some time, it received notice on 23 June 2017 of a reassessment for the fiscal years from the fiscal year ended March 2011 through the fiscal year ended March 2015. Accordingly, it reflected in its financial statements for the fiscal year ended March 2017 the ¥8.5 billion in additional taxes for those five years, together with estimated taxes for the fiscal years ended March 2016 and March 2017 on the assumption that similar taxation would apply. For fiscal years from the fiscal year ended March 2018 onward, estimated tax amounts have been reflected in the financial statements as necessary.」
While continuing the action seeking cancellation of the reassessment under the transfer pricing rules, the company continues to reflect estimated tax amounts for subsequent fiscal years in its financial statements as necessary. - FY2018RestatedAnnual report
「Although the company expects that reaching this conclusion will take some time, it received notice on 23 June 2017 of a reassessment for the fiscal years from the fiscal year ended March 2011 through the fiscal year ended March 2015. Accordingly, it reflected in its financial statements for the fiscal year ended March 2017 the ¥8.5 billion in additional taxes for those five years, together with estimated taxes for the fiscal years ended March 2016 and March 2017 on the assumption that similar taxation would apply. It also recognized in income taxes, inhabitant taxes and enterprise taxes the estimated tax amount for the current fiscal year.」
The company continues to recognize the additional taxes based on the reassessment and the estimated tax amount for the current fiscal year. - FY2018-Q3RestatedAnnual report
「It also recognized in income taxes, inhabitant taxes and enterprise taxes the estimated tax amount relating to the nine months of the current fiscal year.」
As part of its response to the reassessment under the transfer pricing rules, the company continues to recognize additional taxes and other amounts for subsequent fiscal years, as well as the estimated tax amount relating to the nine months. - FY2018-Q2RestatedAnnual report
「Although the company expects that reaching this conclusion will take some time, it received notice on 23 June 2017 of a reassessment for the fiscal years from the fiscal year ended March 2011 through the fiscal year ended March 2015. Accordingly, it reflected in its financial statements for the fiscal year ended March 2017 the ¥8.5 billion in additional taxes for those five years, together with estimated taxes for the fiscal years ended March 2016 and March 2017 on the assumption that similar taxation would apply. It also recognized in income taxes, inhabitant taxes and enterprise taxes the estimated tax amount relating to the first six months of the current fiscal year.」
The company continues to recognize additional taxes and other amounts based on the reassessment, as well as the estimated tax amount relating to the first six months. - FY2018-Q1RestatedAnnual report
「Although the company expects that reaching this conclusion will take some time, it received notice on 23 June 2017 of a reassessment for the fiscal years from the fiscal year ended March 2011 through the fiscal year ended March 2015. Accordingly, it reflected in its financial statements for the fiscal year ended March 2017 the ¥8.5 billion in additional taxes for those five years, together with estimated taxes for the fiscal years ended March 2016 and March 2017 on the assumption that similar taxation would apply. It also recognized in income taxes, inhabitant taxes and enterprise taxes the estimated tax amount relating to the first three months of the current fiscal year.」
Additional taxes and other amounts based on the notice of reassessment received on 23 June 2017 were reflected in the previous fiscal year's financial statements, and the estimated tax amount for the current quarter was also recognized in income taxes and other taxes. The company continues to address the transfer pricing taxation that has already materialized. - FY2017MaterialisedAnnual report
「Because the company received notice on 23 June 2017 of a reassessment for the fiscal years from the fiscal year ended March 2011 through the fiscal year ended March 2015, it reflected in its financial statements for the fiscal year ended March 2017 the ¥8.5 billion in additional taxes for those five years, together with estimated taxes for the fiscal years ended March 2016 and March 2017 on the assumption that similar taxation would apply.」
The risk of reassessment for subsequent fiscal years materialized as an actual notice of reassessment, and the ¥8.5 billion in additional taxes for five years and other amounts were reflected in the financial statements. - FY2017-Q3AdvancedAnnual report
「However, because the refund of corporate and local taxes and other amounts was limited to approximately ¥100 million, the company believes the entire assessment should be revoked and filed an action with the Tokyo District Court on 20 December 2016 seeking cancellation of the reassessment in order to obtain a refund of the remaining amount.」
The company has progressed from considering measures to obtain a refund of the remaining amount to filing an action with the Tokyo District Court on 20 December 2016 seeking cancellation of the reassessment. - FY2017-Q2RestatedAnnual report
「However, even after taking the ruling into consideration, the company has determined that its position remains reasonable and is considering measures to obtain a refund of the remaining amount, although it expects that final resolution of the matter will still take some time. On the other hand, because differences with the tax authorities' position remain for subsequent fiscal years from 1 April 2010 onward, there is a risk of reassessment.」
While considering measures to obtain a refund of the remaining amount, the risk of reassessment for subsequent fiscal years remains. - FY2017-Q1First statedAnnual report
「The ruling partially revokes the assessment, and a refund of approximately ¥100 million in corporate and local taxes is expected. Having determined that the company's position remains sound and reasonable even after taking the ruling into consideration, the company is considering measures to obtain a refund of the remaining amount. On the other hand, there is a risk that the tax authorities may issue reassessments for subsequent fiscal years from 1 April 2010 onward.」
The company has already paid approximately ¥7.9 billion, including local taxes, under reassessments based on transfer pricing rules for prior fiscal years, and has received a refund of approximately ¥1.4 billion relating to its U.S. subsidiary. A refund of approximately ¥100 million is expected for its Polish subsidiary following a partial revocation, while the company has disclosed the risk of reassessments for subsequent fiscal years.