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April - June 2012

Takeda Announces the Conclusion of Reinvestigation Relating to the Correction Notice on Transfer Pricing

Osaka, Japan, April 6, 2012 – Takeda Pharmaceutical Company Limited (“Takeda”) announced today a milestone in its transfer pricing dispute with respect to certain transactions of Prevacid, a drug for the treatment of peptic ulcers. The subject transactions were between Takeda and TAP Pharmaceutical Products Inc.*1 (“TAP”). In November 2011, Takeda re-opened a suspended reinvestigation process*2 concerning the correction notice*3 received in 2006 from the Osaka Regional Tax Bureau (“ORTB”) on the Prevacid transactions. The original reinvestigation process had previously been placed on hold so that Takeda could seek relief through the Mutual Agreement Procedure (“MAP”), however, the MAP did not result in any agreement between the tax authorities of Japan and the United States. Takeda has been asserting the legitimacy of the Takeda position to the ORTB.

Today, Takeda received notice that the ORTB has concluded the reinvestigation with a decision to reduce the original assessment of ¥122.3 billion in taxable income by the amount of ¥97.7 billion. As a result, Takeda expects a refund of ¥57.1 billion, tax and interest combined.

Takeda will consider the contents of the notice and decide on possible further actions.

  • *1 TAP had been a fifty-fifty joint venture between Abbott Laboratories and Takeda America Holdings, Inc. (“TAH”), a wholly owned subsidiary of Takeda located in New York. As a result of the April 2008 dissolution of the TAP joint venture, TAP became a 100% subsidiary of TAH. Also in June 2008, TAP was subsequently merged into Takeda Pharmaceuticals North America, Inc. (“TPNA”), a 100% subsidiary of TAH located in Illinois. In January 2012, TPNA changed its name to Takeda Pharmaceuticals U.S.A. Inc.
  • *2 In response to the Correction Notice, Takeda filed a request for reinvestigation with the ORTB in August 2006. However, this process was placed on hold in order to apply for the MAP in July 2008.
  • *3 Takeda received the Correction Notice from the ORTB based on their conclusion that Takeda earned an under-allocated proportion of the profits earned in the U.S. market in relation to product supply and license transactions of Prevacid between Takeda and TAP over the six-year period from the fiscal year ending March 2000 through the fiscal year ending March 2005. Total additional tax due, including local tax, was ¥57.1 billion. Takeda paid these additional taxes in July 2006.

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