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The discussion of our business and operations should be read together with the risk factors and contained in our annual report on Form 10-K for the fiscal year ended June 30, 2021 , which was filed with the SEC and describe various material risks and uncertainties to which we are or may become subject.
−Removed: As of March 31, 2021, there have been no further material changes to such risk factors, except as follows:
−Removed: We are subject to tax audits by various tax authorities in many jurisdictions.
−Removed: Our income tax returns are based on calculations and assumptions that require significant judgment, and are subject to audit by various tax authorities.
−Removed: In addition, the calculation of our tax liabilities involves dealing with uncertainties in the application of complex tax laws.
−Removed: We regularly assess the potential outcomes of examinations by tax authorities in determining the adequacy of our provision for income taxes.
−Removed: We are under audit by the Australian Taxation Office (the “ATO”) for the years 2009 to 2018 (the “Audit Period”).
−Removed: The audits primarily involve a transfer pricing dispute in which the ATO asserts we should have paid additional Australian taxes on income derived from our Singapore operations.
−Removed: The ATO issued Notices of Amended Assessments for the tax years 2009 to 2013 seeking a total of $266.0 million, consisting of $151.7 million in additional income tax and $114.3 million in penalties and interest.
−Removed: The 2014 to 2018 periods are still under audit and we have not yet received any Notices of Amended Assessments relative to those periods.
−Removed: A total of $98.8 million in tax has been prepaid in relation to the Audit Period, which is consistent with ATO procedural audit practice.
−Removed: We do not agree with the ATO’s assessments and continue to believe we are more likely than not to be successful in defending our position if the matter progresses to litigation.
−Removed: However, if we are not successful, we will be required to pay some or all of the additional income tax, accrued interest and penalties, including potential additional amounts relating to the 2014 to 2018 periods.
−Removed: To that end, we are engaged in ongoing discussions with the ATO to resolve the dispute for the entire Audit Period.
−Removed: Given the stage of those discussions, during the three and nine months ended March 31, 2021, we recorded $395.9 million of gross unrecognized tax benefits, including $53.3 million of accrued interest and penalties, associated with the ATO audits for the Audit Period.
−Removed: This amount reflects our estimate of the potential tax liability and is subject to change.
−Removed: If recognized, we estimate that approximately $254.8 million of unrecognized tax benefits would affect our effective tax rate, which represents the $395.9 million of gross unrecognized tax benefits noted previously, adjusted for tax credits and deductions of $141.1 million.
−Removed: We have elected to recognize interest and penalties related to unrecognized tax benefits as a component of income taxes.
−Removed: The timing and resolution of the ATO audits are inherently uncertain, and the amounts we might ultimately pay, if any, upon resolution of issues raised by the ATO may differ materially from the amounts accrued.
−Removed: Although it is expected that the amount of unrecognized tax benefits may change in the next 12 months, an estimate of the range of the possible change cannot be made
+Added: As of September 30, 2021, there have been no further material changes to such risk factors.
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