AstraZeneca has been informed that the UK and US governments’ tax authorities have agreed to the terms of an advance-pricing agreement regarding transfer-pricing arrangements for AstraZeneca’s US business for the 13-year period from 2002 to the end of 2014. AstraZeneca has concurrently reached agreement with the US tax authorities on a related valuation matter arising on integration of its US businesses in 2000 following the global AstraZeneca merger in 1999.
Based on these agreements, AstraZeneca expects to pay a net amount of $1.1 billion to resolve all US transfer pricing and related valuation matters for all periods from 2000 to the end of 2010. This net amount reflects expected US tax payments and updated estimates of corresponding tax refunds in other jurisdictions. The payments arising from these agreements are expected to be made during 2011.
AstraZeneca had allocated a net accrual for transfer pricing and other international tax contingencies of $2.3 billion, according to its 2010 financial statements. Because the amount of the settlement for this particular dispute is now less than it had anticipated, the company will add $500 million to its first-quarter earnings, according to a Mar. 28, 2011, AstraZeneca press release.