INTERNATIONAL PHARMACEUTICAL COMPANY Perrigo has been hit with a tax demand from Revenue for €1.6 billion.

The company was formerly known as Elan Pharma before it was acquired by Perrigo in 2013. 

It filed a submission with the US Securities and Exchange Commission yesterday confirming that it had been issued with a Notice of Amended Assessment by the Irish Revenue Commissioners.

The full amount of the revised bill is €1.6 billion. 

The matter relates to the 2013 sale by Elan of the intellectual property the MS drug Tysabri.

It was taxed as trading income at 12.5% but Revenue said it should have been treated as a chargeable gain, which has a higher rate. 

Perrigo strongly disagrees with Revenue’s assessment. 

“Perrigo strongly disagrees with this assessment and believes that the NoA is without merit,” it said in a statement.

“The Company asserts that Irish Revenue’s position is incorrect as a matter of law, based
upon applicable case law, as well as both Irish Revenue published guidance and
their related published precedents.

“In addition, no payment of any amount related to this assessment is required to be made, if at all, until all applicable proceedings have been completed, which could take a number of years.

The Company will file an appeal and intends to contest the assessment vigorously through all available administrative and judicial avenues.

When asked for comment, a spokesperson for Revenue said that it was precluded from commenting on the tax affairs of any individual or entity under law.