Amadeus IT Holding, S.A. and Subsidiaries - Investor relations at ...

AMADEUS IT HOLDING, S.A. AND SUBSIDIARIES
NOTES TO THE CONSOLIDATED ANNUAL ACCOUNTS FOR THE YEARS ENDED
DECEMBER 31, 2011, AND 2010
(EXPRESSED IN THOUSANDS OF EUROS - KEUR)
22. TAXATION
The companies that make up the Group are all individually responsible for their own
tax assessments in their countries of residence, without any worldwide Group tax
consolidation. The statute of limitations varies from one company to another,
according to local tax laws in each case. Tax returns are not considered definitive
until the statute of limitations expires or they are accepted by the Tax Authorities.
Independently that the fiscal legislation is open to different interpretations, it is
estimated that any additional fiscal liability, as may arise from a possible tax audit,
will not have a significant impact on the consolidated financial statements taken as a
whole.
The French Tax Authorities issued tax reassessments without penalties to the
subsidiary Amadeus s.a.s. due to transfer pricing adjustments for fiscal years 2003
and 2004 (in December 2006), 2005 and 2006 (in July 2008), 2007 (in May 2011),
and 2008 (the preliminary reassessment has been received in December 2011).
During the year ended December 31, 2011, the French Tax Authorities have started
the review of the years 2009 and 2010, for which no tax reassessment has been
issued before the end of the year. In all of the cases, irrespective of the final outcome
of the administrative/legal process initiated by the Group, in the event that the tax
reassessment becomes final, the potential effect on the consolidated financial
statements as of December 2011 would be partially mitigated by the bilateral tax
adjustment to be applied at group level. In this respect, the Group initiated in October
2007 (for fiscal years 2003 and 2004), and in July 2009 (for fiscal years 2005 and
2006), the EU Arbitration Convention and, also, has initiated the Mutual Agreement
procedures between Spain and France. According to French law, when the
Arbitration procedure is initiated, the payment of the tax reassessment is suspended
until the end of the procedure, and also the interest accrued during the period of time
involved.
In September 2010, the German Tax Authorities started a tax audit in Amadeus Data
Processing GmbH, corresponding to years 2007 to 2009. In 2011 the tax audit has
been closed without significant tax liability for the Group. During the year 2010, the
German Tax Authorities finalized the tax audit for years 2003 to 2006 without
significant tax liabilities for the Group.
On February 1, 2010, the Spanish Tax Authorities initiated the tax audit procedures
in Amadeus IT Holding, S.A. as parent company of the Spanish Tax Consolidation
Group, and in the other companies belonging to this same Group, during 2011 were
still on-going. The taxes and periods covered by this review are the following:
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