Transfer Pricing Tax Audit of U.S. Subsidiary and Additional Tax Liability
First written in FY2020-Q1. 1 of 4 entries say "Materialised", first in FY2020-Q2. Latest entry: FY2021.
The whole theme swung hardest in 2023: 2 of 12 companies on the "Worse" side.
7 other companies' latest entry also says "Mitigated".
- FY2021MitigatedAnnual report
「The appeal filed in December 2019 was upheld by the Supreme Court in February 2021, and, following the final judgment in the company's favor, ¥357 million in negative income taxes for prior periods was recorded.」
Separately from the risk of an additional tax burden related to the transfer pricing tax audit of the U.S. subsidiary, a reversal of income taxes for prior periods arose following the company's victory in the Indonesian tax litigation. - FY2020Update to estimated additional tax burdenAnnual report
「The company is under investigation by the U.S. tax authorities in relation to transfer pricing and has recorded ¥575 million as income taxes for prior periods, representing the amount of estimated additional tax burden currently considered likely to arise that exceeds the amount recorded in the previous consolidated fiscal year.」
¥575 million in estimated additional tax burden related to the transfer pricing tax audit of the U.S. subsidiary was recorded. - FY2020-Q2MaterialisedAnnual report
「Allegro MicroSystems, Inc., a consolidated subsidiary of the company, is under investigation by the U.S. tax authorities in relation to transfer pricing for transactions with the company and its consolidated subsidiaries. Of the estimated additional tax burden currently considered likely to arise, the company has recorded ¥574 million as income taxes for prior periods, representing the amount exceeding that recorded in the previous consolidated fiscal year.」
¥574 million in estimated additional tax burden related to the transfer pricing tax audit of the U.S. subsidiary was recorded as income taxes for prior periods. - FY2020-Q1First statedAnnual report
「Allegro MicroSystems, Inc., a consolidated subsidiary of the company, is under investigation by the U.S. tax authorities in relation to transfer pricing for transactions with the company and its consolidated subsidiaries. Of the estimated additional tax burden currently considered likely to arise, the company has recorded as income taxes for prior periods the amount exceeding that recorded in the previous consolidated fiscal year.」
In connection with the transfer pricing tax audit by the U.S. tax authorities, ¥581 million in estimated additional tax burden exceeding the amount recorded in the previous fiscal year was recorded as income taxes for prior periods.