IRS gets $1.1 billion in transfer pricing case

U.K. based AstraZeneca plc announced that it will pay the Internal Revenue Service $1.1 billion to settle all transfer pricing issues for 2000-10, according to a March 28 statement released by the company.

Tax authorities in the U.S. and the U.K. agreed on an advance pricing agreement regarding transfers between AstraZeneca’s international subsidiaries for the period from 2002 through 2014, the company said. AstraZeneca also agreed with U.S. tax authorities on a related valuation matter stemming from the integration of its U.S. businesses after the merger that created the company in 1999.

Japan agrees to refund ¥ 1.8 billion to Capcom under the transfer pricing mutual agreement procedure with IRS

Mutual agreement procedure as negotiated by tax treaty partners was at its best when IRS and National Tax Authority of Japan recently agreed that Japan should not have imposed certain transfer pricing adjustments in case of Capcom, a leading game software company. As a result of mutual agreement Japan has agreed to refund 1.8 billion Yens (around $20 million) to Capcom as stated by Company spokesman and reported by BNA.