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AstraZeneca discusses APA settlement

December 16, 2011

Matthew Gilleard - TP Week

Not much has been said about what the settlement means for other taxpayers and their dealings with HM Revenue & Customs (HMRC).

The dispute, dating back to 2002, settled last week when the UK and US tax authorities agreed to the terms of a bilateral advance pricing agreement (APA).

Based on the APA, which will apply retrospectively and prospectively to cover the 13 year period from 2002 to the end of 2014, the Anglo-Swedish pharmaceuticals company will pay $1.1 billion to resolve its outstanding US transfer pricing issues and related valuation matters. These payments are scheduled to be made during 2011. No further breakdown of the payment has been disclosed.

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