The IRS is withdrawing an $843 million income tax adjustment related to Perrigo Company Plc’s transfer pricing, the pharmaceutical company reported Tuesday in a filing.
In 2019 the IRS sent notices of proposed adjustments for the tax years 2011, 2012, and 2013 to Athena Neurosciences LLC, which was acquired by Elan Corporation Plc in 1996. Perrigo, in turn, acquired Elan in 2013.
The IRS was arguing that Elan should have paid a “substantially” higher royalty rate for exploiting intangibles from Athena. In particular, the IRS was looking at royalties related to the drug Tysabri, Perrigo said in a filing to ...
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