Transfer Pricing Reassessment Involving U.S. Subsidiary and Expected Elimination of Double Taxation
First written in FY2017-Q3. 1 of 3 entries say "Mitigated", first in FY2017. Latest entry: FY2018.
0 other companies' latest entry also says "Restated".
- FY2018RestatedAnnual report
「Regarding the transfer pricing adjustment imposed in a prior fiscal year in connection with transactions between the Company and its U.S. subsidiary, the Company received notification from the National Tax Agency dated 14 February 2017 that mutual agreement discussions between the tax authorities of Japan and the United States had reached agreement.」
The Company reconfirmed the agreement reached in the mutual agreement discussions between the Japanese and U.S. tax authorities and the treatment of the ¥405 million difference from the expected refund amount. - FY2017MitigatedAnnual report
「Regarding the transfer pricing adjustment imposed in a prior fiscal year in connection with transactions between the Company and its U.S. subsidiary, the Company received notification from the National Tax Agency dated 14 February 2017 that mutual agreement discussions between the tax authorities of Japan and the United States had reached agreement.」
The matter progressed from the previous expectation that double taxation would be eliminated to agreement in the mutual agreement discussions between the Japanese and U.S. tax authorities, and the ¥405 million difference from the final refund amount was reflected in income taxes. - FY2017-Q3First statedAnnual report
「Regarding the transfer pricing adjustment imposed in a prior fiscal year in connection with transactions between the Company and its U.S. subsidiary, mutual agreement discussions between the tax authorities of Japan and the United States progressed toward agreement, making it likely that double taxation will be eliminated. Accordingly, the difference of ¥405 million between the expected refund and the amount of the expected refund recorded in prior fiscal years, shown as a decrease, is included in “Income taxes” for the cumulative third quarter of the fiscal year under review.」
The transfer pricing adjustment occurred in a prior fiscal year, and the Company expects double taxation to be eliminated as mutual agreement discussions between the Japanese and U.S. tax authorities progress. The ¥405 million difference has been reflected in income taxes for the current fiscal year.