April - June 2012
April 6, 2012
Takeda Pharmaceutical Company Limited
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.