INCOME TAXES

Our effective tax rate represents the net effect of the mix of income earned in various tax jurisdictions that are subject to a wide range of income tax rates.

We recognize interest expense and penalties related to income tax matters in income tax expense.

For the three and six months ended December 31, 2015, and 2014, we recognized the following amounts as income tax-related interest expense and penalties:



	Three Months Ended December 31,						Six Months Ended December 31,
	2015			2014			2015			2014
Interest expense	$	1,195		$	1,507		$	2,972		$	3,511
Penalties expense (recoveries)	(2,596		)	(343		)	(2,726		)	(295		)
Total	$	(1,401	)	$	1,164		$	246		$	3,216

As of December 31, 2015 and June 30, 2015, the following amounts have been accrued on account of income tax-related interest expense and penalties:



	As of December 31, 2015		As of June 30, 2015
Interest expense accrued *	$	30,753	$	28,827
Penalties accrued *	$	1,756	$	5,040


*	These balances have been included within "Long-term income taxes payable" within the Condensed Consolidated Balance Sheets.

We believe that it is reasonably possible that the gross unrecognized tax benefits, as of December 31, 2015, could decrease tax expense in the next 12 months by $5.4 million, relating primarily to the expiration of competent authority relief and tax years becoming statute barred for purposes of future tax examinations by local taxing jurisdictions.

Our four most significant tax jurisdictions are Canada, the United States, Luxembourg and Germany. Our tax filings remain subject to audits by applicable tax authorities for a certain length of time following the tax year to which those filings relate. The earliest fiscal years open for examination are 2008 for both Canada and Germany, 2010 for the United States, and 2011for Luxembourg.

We are subject to tax audits in all major taxing jurisdictions in which we operate and currently have tax audits open in Canada, the United States, France, Spain, Germany, India, the Netherlands and Japan. On a quarterly basis we assess the status of these examinations and the potential for adverse outcomes to determine the adequacy of the provision for income and other taxes. Statements regarding the United States audits are included in note 13.

The timing of the resolution of income tax audits is highly uncertain, and the amounts ultimately paid, if any, upon resolution of the issues raised by the taxing authorities may differ from the amounts accrued. It is reasonably possible that within the next 12 months we will receive additional assessments by various tax authorities or possibly reach resolution of income tax audits in one or more jurisdictions. These assessments or settlements may or may not result in changes to our contingencies related to positions on tax filings. The actual amount of any change could vary significantly depending on the ultimate timing and nature of any settlements. We cannot currently provide an estimate of the range of possible outcomes. For more information relating to certain tax audits, please refer to note 13.

As at December 31, 2015, we have provided $12.8 million (June 30, 2015—$12.1 million) in respect of both additional foreign withholding taxes or deferred income tax liabilities for temporary differences related to the undistributed earnings of certain non-United States subsidiaries, and planned periodic repatriations from certain United States and Luxembourg subsidiaries, that will be subject to withholding taxes upon distribution. We have not provided for additional foreign withholding taxes or deferred income tax liabilities related to undistributed earnings of all other non-Canadian subsidiaries, since such earnings are considered permanently invested in those subsidiaries, or are not subject to withholding taxes. It is not practicable to reasonably estimate the amount of additional deferred income tax liabilities or foreign withholding taxes that may be payable should these earnings be distributed in the future.

The effective tax rate (which is the provision for taxes expressed as a percentage of net income before taxes) decreased to 4.4% for the three months ended December 31, 2015, compared to 19.7% for the three months ended December 31, 2014. The decrease to tax expense of $14.2 million is primarily the result of (i) variances in income among jurisdictions, resulting in the impact of foreign rates in the amount of $8.8 million, and (ii) a decrease in the net expense of unrecognized tax benefits with related interest and penalties in the amount of $11.7 million. These impacts were partially offset by an increase in valuation allowance in the amount of $1.8 million, tax filings in excess of amounts previously booked of $1.9 million and additional accruals in respect of future distributions from foreign subsidiaries of $1.2 million. The remainder of the differences are due to normal course movements and non-material items.

The effective tax rate decreased to 10.6% for the six months ended December 31, 2015, compared to 20.4% for the six months ended December 31, 2014. The decrease to tax expense of $20.4 million is primarily the result of (i) lower net income, having an impact of $14.1 million, and (ii) a decrease in the net expense of unrecognized tax benefits with related interest and penalties in the amount of $13.9 million. These impacts were partially offset by an increase in valuation allowance in the amount of $3.1 million, tax filings in excess of amounts previously booked of $2.0 million and additional accruals in respect of future distributions from foreign subsidiaries of $1.1 million. The remainder of the differences are due to normal course movements and non-material items.