Komori
Tokyo Electron Limited (8035) · RiskMitigated

Transfer Pricing Reassessment Concerning Korean Subsidiary and Prospects for Eliminating Double Taxation

First written in FY2019-Q3. 1 of 2 entries say "Mitigated", first in FY2019. Latest entry: FY2019.

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How it moved
ProgressHeldSoftenedWorseFirst statedFY2019-Q32019: 22019
Same theme, other companies
Risk of additional taxation arising from international tax and transfer-pricing rulesA theme 32 companies write about · 34 as a headwind · 0 as a tailwind

The whole theme swung hardest in 2018: 3 of 12 companies on the "Worse" side.

6 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 32 companies compared. The sentences above are computed from all 32.
Full recordFilings, disclosures and news, newest first
  1. FY2019MitigatedAnnual report

    「Regarding the transfer pricing adjustment under the transfer pricing tax rules involving the company and its Korean subsidiary in prior fiscal years, the company received notification from the National Tax Agency that mutual agreement proceedings between the tax authorities of Japan and South Korea had reached an agreement effective 24 January 2019. Accordingly, the difference of ¥862 million between the confirmed refund amount and the refund amount recorded in prior fiscal years was included in income taxes, inhabitant taxes and enterprise taxes for the consolidated fiscal year.」

    Mutual agreement proceedings between the Japanese and South Korean tax authorities reached an agreement, advancing the process for eliminating double taxation from the expected stage to the agreed stage. The ¥862 million difference was reflected in income taxes and other taxes.
  2. FY2019-Q3First statedAnnual report

    「Regarding the transfer pricing adjustment under the transfer pricing tax rules involving the company and its Korean subsidiary in prior fiscal years, mutual agreement proceedings between the tax authorities of Japan and South Korea progressed toward an agreement, and double taxation was expected to be eliminated. Accordingly, the difference of ¥647 million between the expected refund and the refund amount recorded in prior fiscal years was included in income taxes for the nine-month period of the current consolidated fiscal year.」

    Regarding the transfer pricing adjustment under the transfer pricing tax rules involving the Korean subsidiary in prior fiscal years, mutual agreement proceedings between the Japanese and South Korean tax authorities progressed, and the expected elimination of double taxation and the reflection of the ¥647 million difference in income taxes were disclosed for the first time.
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