Komori
Sanken Electric (6707) · RiskMitigated

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.

4entries
3years
0from disclosures
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How it moved
ProgressHeldSoftenedWorseFirst statedFY2020-Q1MaterialisedFY2020-Q2OtherFY20202019: 220192020: 120202021: 12021
Same theme, other companies
Risk of Additional Taxation under International Tax and Transfer Pricing RulesA theme 40 companies write about · 42 as a headwind · 0 as a tailwind

The whole theme swung hardest in 2023: 2 of 12 companies on the "Worse" side.

7 other companies' latest entry also says "Mitigated".

Ridges = years it wrote progress, valleys = years it wrote worse. Most hopeful companies at the back. Drag to turn, scroll to zoom, right-drag to pan. On a phone, two fingers turn and pinch to zoom; one finger scrolls the page.
Showing 14 of the 40 companies compared. The sentences above are computed from all 40.
Full recordFilings, disclosures and news, newest first
  1. 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.
  2. 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.
  3. 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.
  4. 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.
Moved together

"Expansion of Semiconductor Products for Automobiles and White Goods" moved the same way as this thread, in the same document, in 2 of its 4 moves.

222222★123456
  1. ★This thread
  2. 1Expansion of Semiconductor Products for Automobiles and White Goods2×
  3. 2Concerns About the Global Economy, Including the Chinese Economic Slowdown2×
  4. 3Deterioration in global market conditions and supply-demand adjustments across the supply chain2×
  5. 4Increase in Foreign Exchange Losses2×
  6. 5Recognition of Extraordinary Losses Associated with Restructuring2×
  7. 6Increase in Fixed-Cost Burdens from Upfront Development and Capital Expenditure2×

★ is this thread; numbers match the list above. The number on a line is how many documents both moved the same way in; lines between the other threads count the documents they moved together in too. Threads that move together often sit closer.

When this could move next
Sanken Electric's next results are scheduled for 2026-11-11. Read the earnings preview
News
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