The company, in a regulatory filing, said it is in the process of negotiating with the US Internal Revenue Service. The notices correspond to tax years 2004 to 2013. Credit: Mats Wiklund / Shutterstock Microsoft is planning to appeal a claim of $28.9 billion in back taxes that it has received from the US Internal Revenue Service (IRS), the company said on Wednesday. The Notices of Proposed Adjustment were received on September 26, related to intercompany pricing or transfer pricing, Microsoft said in a regulatory filing. The IRS is seeking an additional tax payment of $28.9 billion, plus penalties and interest for the period between 2004 and 2013. “As of September 30, 2023, we believe our allowances for income tax contingencies are adequate,” the company said. “We disagree with the proposed adjustments and will vigorously contest the Notices of Proposed Adjustment (NOPAs) through the IRS’s administrative appeals office and, if necessary, judicial proceedings.” Intercompany pricing or transfer pricing is a way for companies to allocate their profits between their operations in different countries and jurisdictions. The IRS claims that Microsoft may have breached its prescribed regulations for transfer pricing. “Many large multinationals use cost-sharing because it reflects the global nature of their business. Because our subsidiaries shared in the costs of developing certain intellectual property, under those IRS cost-sharing regulations, the subsidiaries were also entitled to the related profits,” Daniel Goff, Microsoft’s corporate vice president of worldwide tax and customs, wrote in a blog post that was attached to the SEC filing. The notices are the first detailed information that Microsoft has received from the IRS about the agency’s explanations of their views about the issues in question, Goff said. “The IRS’s proposed adjustments do not represent a final determination. Not reflected in the proposed adjustments are taxes paid by Microsoft under the Tax Cuts and Jobs Act (TCJA), which could decrease the final tax owed under the audit by up to $10 billion,” Goff wrote. Microsoft, which claims to have followed all the IRS’ rules and paid the taxes it owed in the US and around the world, is planning to appeal to the IRS’ Appeals division. The company claims to have paid over $67 billion in taxes in the US since 2024. The IRS Appeals process is expected to take several years to complete, Goff wrote, adding that if the parties are unable to come to an agreement, Microsoft would be looking to move courts over the issue. In the regulatory filing, Microsoft said that presently it doesn’t see any impact on its tax contingencies arising from these issues within the next 12 months. Related content feature TransUnion transforms its business with IT On the heels of its Neustar acquisition, the consumer credit reporting agency seeks to give customers access to its troves of consumer data to fuel next-generation services through solutions platform OneTru. By Paula Rooney Apr 26, 2024 6 mins Financial Services Industry Digital Transformation Artificial Intelligence feature The 10 highest-paying industries for IT talent The tech industry isn’t the only hot spot for IT jobs, as there’s a growing demand for IT pros across every industry. These 10 verticals pay the most for IT roles, according to data from Dice. By Sarah K. White Apr 26, 2024 7 mins Salaries IT Jobs Careers brandpost Sponsored by Palo Alto Networks M&A action is gaining momentum, are your cloud security leaders prepared? Direct visibility is critical in M&A, and cloud-native application protection platforms (CNAPP) are ideal to provide this capability. By Amol Mathur, SVP & GM of Prisma Cloud, Palo Alto Networks Apr 25, 2024 4 mins Cloud Management news CIOs eager to scale AI despite difficulty demonstrating ROI, survey finds CIOs prioritize integrating AI into their organizations alongside cybersecurity, according to a new survey. By Sandeep Budki Apr 25, 2024 5 mins Artificial Intelligence PODCASTS VIDEOS RESOURCES EVENTS SUBSCRIBE TO OUR NEWSLETTER From our editors straight to your inbox Get started by entering your email address below. Please enter a valid email address Subscribe