Double Taxation and Mutual Agreement Procedures under the Transfer Pricing Regime
First written in FY2016. 2 of 3 entries say "Materialised", first in FY2016. Latest entry: FY2019.
Smc moved to the "Worse" side of this theme in 2019, 7 years before the typical company in this theme (2026).
The whole theme swung hardest in 2018: 3 of 12 companies on the "Worse" side.
2 other companies' latest entry also says "Materialised".
- FY2019MaterialisedAnnual report
「Net income attributable to owners of the parent was ¥130,631 million, down 4.6% year on year. The main factor was an increase in the corporate income tax burden related to the transfer pricing regime.」
The increase in the corporate income tax burden related to the transfer pricing regime again appeared in the results as a factor behind the decline in net income. The amount of the increase was not separately disclosed. - FY2017-Q1MitigatedAnnual report
「The quarterly net income attributable to owners of the parent was ¥24,851 million, down 19.0% year on year, mainly due to the recognition of ¥6,898 million in prior-period corporate income taxes and other taxes refunded following the Japan-Korea mutual agreement concerning the transfer pricing adjustment.」
The company recognized ¥6,898 million in corporate income tax and other tax refunds in profit or loss based on the Japan-Korea mutual agreement, marking progress in addressing the tax burden arising from the transfer pricing regime. - FY2016MaterialisedAnnual report
「The company and SMC Korea had filed for mutual agreement procedures under the Japan-Korea tax treaty to avoid double taxation, and received a notice dated 23 June 2016 from the authorities stating that agreement had been reached through mutual consultations with the authorities of the other country. Based on this mutual agreement, the company and SMC Korea expect a refund of ¥6.9 billion in corporate income taxes and other taxes.」
The company had paid approximately ¥6.6 billion in Japan and approximately ¥1.6 billion in Korea as a result of transfer pricing adjustments for prior years, and expects a refund of ¥6.9 billion under the mutual agreement.