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Funai Electric Co., Ltd. (hereinafter referred to as the “Company”) had objected to the reassessment notice from the Regional Commissioner of the Osaka Regional Taxation Bureau based on the decision that the Company’s Hong Kong-based subsidiary did not meet the conditions that would allow it to be covered by the exceptions under the anti-tax haven taxation. The Company therefore filed an action with the Osaka District Court seeking the rescission of such tax assessment notice, pursuant to applicable laws and regulations. With respect to this action, the court dismissed the claims of the Company on June 24, 2011.
The Company filed an appeal with the Osaka High Court. With respect to this action, on July 20, 2012, the court dismissed the claims of the Company. Afterward, on August 1, 2012, the Company filed an appeal and a petition for acceptance of final appeal with the Supreme Court.
Today, the Company received a decision from the Supreme Court dated December 11 stating the appeal had been dismissed.

1. Development of the Case

2. Details of Decision

(1) The appeal was dismissed.
(2) The petition for final appeal was not accepted.
(3) The appellant / petitioner shall bear expenses related to the appeal and petition for final appeal.

3. Prospects

There is no impact on performance.