US drugmaker Perrigo has said that Revenue has rejected an offer to settle a €1.64 billion tax bill it claims the company owes for back taxes.
In a filing to the Securities and Exchange Commission, the firm said Irish tax authorities verbally indicated that a written settlement offer made through its tax adviser at the end of April would not be accepted as presented.
A formal response would be transmitted in due course.
The development came just days after the chief executive of Perrigo disclosed that the offer had been made to the tax authority at the end of last month.
Last November Perrigo lost a High Court challenge to the 2018 tax bill, which arose out of the company's tax treatment of revenue arising after the sale in 2013 by Elan of its intellectual property stake in a multiple sclerosis drug to Biogen.
Elan was also bought by Perrigo in 2013, eight months after the Biogen deal.
Revenue found that the intellectual property sales by Elan were taxed as trading income at 12.5%, when they should have been treated as a chargeable gain at a rate of 33%.
Perrigo still has an outstanding appeal before the Tax Appeals Commission.
"Perrigo will review Irish Revenue's formal response to Perrigo's offer when received and expects further discussions and correspondence with Irish Revenue prior to the TAC hearing in November," it said.
"There can be no assurances that any settlement is possible on terms acceptable to Perrigo."
"Unless and until a final settlement is reached, Elan Pharma will vigorously pursue its tax appeal before the TAC, concurrently with any settlement discussions that may occur."
"No payment of any additional tax will be required unless and until required by a settlement or other final determination."
Share in Perrigo were lower this afternoon.
