DRIVEN BASE

Supreme Court Decides on Suit Filed by DENSO Seeking Retraction of Tax Authorities’ Decision on Reassessment of DENSO’s Profits under Anti-tax Haven Rules

Oct. 24, 2017

KARIYA (Japan) ― DENSO Corporation received a notification from the Nagoya Regional Taxation Bureau on June 28, 2010 that DENSO’s subsidiary in Singapore was not subject to the exemptions to the anti-tax haven rules, and thus DENSO was required to amend the total of its reported taxable income for the two fiscal years ending in March 2008 and March 2009, to declare an unreported income of about 11.4 billion yen and pay about 1.2 billion yen in back taxes including local and other taxes.

Dissatisfied with the judgement, DENSO filed a lawsuit for annulment of the decision and on September 4, 2014, the Nagoya District Court ruled in favor of DENSO regarding its Singapore subsidiary subject to the exemptions to the anti-tax haven rules. However on February 10, 2016, the Nagoya High Court ruled in favor of the defendant, rejecting DENSO’s assertions.

Dissatisfied with this, DENSO appealed to the Supreme Court (filing a final appeal and/or petitioning for acceptance of a final appeal).

DENSO today announces that its claims were recognized by the Supreme Court and its assertion was accepted that DENSO’s subsidiary in Singapore was subject to the exemptions to the anti-tax haven rules.

DENSO does not expect any significant impact on its consolidated financial result for the year ending March 31, 2018, although DENSO will receive a tax refund, including local taxes and the additions to taxes as a result of the judgement for the final appeal.

Moreover, DENSO also received a same notification from the Nagoya Regional Taxation Bureau  for the two fiscal years ending in March 2010 and March 2011 under the anti-tax haven rules. On October 18, 2017, DENSO’s assertion was accepted by the Nagoya High Court.

About DENSO Corporation

DENSO Corp., headquartered in Kariya, Aichi prefecture, Japan, is a leading global automotive supplier of advanced technology, systems and components in the areas of thermal, powertrain control, electronics and information and safety. Its customers include all the world's major carmakers. Worldwide, the company has more than 200 subsidiaries and affiliates in 38 countries and regions (including Japan) and employs more than 150,000 people. Consolidated global sales for the fiscal year ending March 31, 2017, totaled US$40.4 billion. Last fiscal year, DENSO spent 9.0 percent of its global consolidated sales on research and development. DENSO common stock is traded on the Tokyo and Nagoya stock exchanges. For more information, go to www.denso.com, or visit our media website at www.denso.com/global/en/news/media-center/