Songa Offshore SE Notes Australian Tax Dispute
Reference is made to Note 4 in the Songa Offshore 2014 Annual Report regarding the Australian Tax Dispute.
The Australian Taxation Office (ATO) raised claims against Songa Offshore for the 2009 year in relation to the global restructure implemented in May 2009, where the Company in Australia changed from an Owner operated structure to a bareboat structure. The potential liability for the ATO’s primary withholding tax avoidance case for the 2009 – 2011 years was estimated at AUD 88.8m, inclusive of interest and penalties.
The ATO also raised an alternative income tax avoidance case, for which the potential liability for the 2009 – 2011 years was estimated at AUD 24.2m, inclusive of penalties and interest.
The dispute, including all matters with the ATO, was settled on 4 September 2015 with Songa Offshore agreeing to make a cash payment of AUD 1.2m (approximately USD 0.8 million). A corresponding provision was made in the second quarter 2015 interim financial statement.