Settlements

ST-324
Siemens AG / Former Com Group (Tax Settlement relating to 2007 Munich case)
Siemens AG
Germany
[tax authorities]
Various
2007
10/04
None
Legal Person
Civil
Tax Settlement ("tatsthliche VerstUdigung")
Tax Settlement (tatsthliche VerstUdigung)
$253,446,100.00
$253,446,100
Taxes Owed
$253,446,100
Taxes Owed
Art.16, Art.26
Art. 1, Art. 2
Tax violations (liability relating to payments in connection with BCAs, other sales-related agreements with third-party intermediaries and other payments relating to the former Com Group at Siemens AG)
Tax violations (liability relating to payments in connection with BCAs, other sales-related agreements with third-party intermediaries and other payments relating to the former Com Group at Siemens AG)
Yes
From Siemens Annual Report 2007 Incl. Consolidated Financial Statements of Siemens AG at 170-171 (30 Nov 2007): "The Company has accounted for income tax-related charges with respect to fiscal 2000-2006 and adjusted comparative amounts for fiscal 2005 and 2006 as summarized below: In October 2007, the Company reached a final settlement (tatsächliche Verständigung) with the German tax authorities regarding the deductibility for tax purposes of certain payments at the former Com Group at Siemens AG with respect to fiscal 2000-2006. Pursuant to the settlement, the Company’s income tax obligation relating to payments in connection with BCAs [Business Consultant Agreements], other sales-related agreements with third-party intermediaries and other payments relating to the former Com Group at Siemens AG was determined to be €179 million. Payments of approximately €449 million were determined to be non-deductible for tax purposes. The Company also recorded interest charges of €12 million related to the tax obligations." (Source: Siemens Annual Report 2007, at 170.