Navigation Menu

Poll

How do you rate your relationship with your CFO

Very good, they understand TP requirements well enough
8%
Good but there's room for improvement
30%
Good but TP is not their main concern
52%
They do not understand the requirements of the TP department
10%


View previous poll results

Skip to Navigation menu Skip to top of page

Forest uses transfer pricing to channel $2 billion through Ireland

October 14, 2008

Forest Laboratories, a US pharmaceutical company, used transfer pricing methods to channel more than $2 billion through its Irish operation in the last financial year

The company reported pre-tax profits of almost $810 million. It paid $22.3 million in corporate tax, the equivalent of a 2.75% tax rate. Forest Laboratories Holdings, an Irish-incorporated subsidiary of the New York listed company, sub-licenses the rights to manufacture drugs to other Forest subsidiaries.

Forest Laboratories acknowledges using Ireland to reduce its tax bill. In its annual report, filed with the SEC, the firm said its overall tax rate for the year was 20%, compared with the US rate of 35%.

‘‘A portion of our earnings is taxed at more favorable rates applicable to the activities undertaken by our subsidiaries based or incorporated in the Republic of Ireland,” said the report. However, the company admits its transfer pricing ‘‘is the subject of an ongoing audit by the Internal Revenue Service’’ in the US.

‘‘Changes in tax laws or in their application or interpretation, such as to the transfer pricing between Forest’s non-US operations and the US, could increase our effective tax rate and negatively affect our results of operations,” it warned.

In connection with the audit, the report confirms that the IRS has issued a revenue agent report which seeks to assess approximately $206.7 million of additional corporation income tax with respect to the company’s 2002 and 2003 fiscal years, excluding interest and penalties.

Free Trial

Sorry. You must be a subscriber to view this article. Alternatively, why not take a free trial? To subscribe and access this article immediately simply click here or call +44(0)207 779 8380.


Email:
Password:

Remember me?
Forgot your password?