The Company is incorporated in Switzerland but operates in various countries with differing tax laws and rates. Further, a portion of the Company's income (loss) before taxes and the provision for (benefit from) income taxes is generated outside of Switzerland.


	Years Ended March 31,
	2021		2020		2019
Current:
Swiss	$	121,199	$	5,474	$	1,364
Non-Swiss	45,056		29,078		24,334
Deferred:

Swiss	31,558		(153,210)		—
Non-Swiss	3,050		(6,739)		(12,138)
Provision for (benefit from) income taxes	$	200,863	$	(125,397)	$	13,560

The difference between the provision for (benefit from) income taxes and the expected tax provision (tax benefit) at the statutory income tax rate of 8.5% is reconciled below (in thousands):


	Years Ended March 31,
	2021		2020		2019
Expected tax provision at statutory income tax rates	$	97,590	$	27,568	$	23,046
Income taxes at different rates	88,760		(5,592)		(10,113)
Research and development tax credits	(3,844)		(4,692)		(5,432)

Executive compensation	4,821		1,582		3,344
Stock-based compensation	(3,161)		(2,735)		(7,288)
Deferred tax effects from TRAF	1,944		(206,792)		—
Valuation allowance	(247)		(538)		1,891
Restructuring charges / (credits)	(5)		12		961
Unrecognized tax benefits	15,978		64,683		8,269

Other, net	(973)		1,107		(1,118)
Provision for (benefit from) income taxes	$	200,863	$	(125,397)	$	13,560

Deferred income tax assets and liabilities consist of the following (in thousands):


	March 31,
	2021		2020
Deferred tax assets:
Tax attributes carryforward	$	42,482	$	73,975
Accruals	79,884		57,923
Depreciation and amortization	1,628		4,831
Tax step-up of goodwill from TRAF	134,122		151,220
Share-based compensation	12,784		10,947
Gross deferred tax assets	270,900		298,896
Valuation allowance	(28,926)		(29,171)
Deferred tax assets after valuation allowance	241,974		269,725
Deferred tax liabilities:
Acquired intangible assets and other	(32,789)		(31,128)
Deferred tax liabilities	(32,789)		(31,128)
Deferred tax assets, net	$	209,185	$	238,597

The canton of Vaud enacted TRAF, a major reform to better align the Swiss tax system with international tax standards, on March 10, 2020 that took effect as of January 1, 2020. The longstanding tax ruling from the canton of Vaud was applicable through December 31, 2019.

Management regularly assesses the ability to realize deferred tax assets recorded in the Company's entities based upon the weight of available evidence, including such factors as recent earnings history and expected future taxable income. In the event that the Company changes its determination as to the amount of deferred tax assets that can be realized, the Company will adjust its valuation allowance with a corresponding impact to the provision for income taxes in the period in which such determination is made.

The Company had a valuation allowance against deferred tax assets of $28.9 million at March 31, 2021, compared to $29.2 million at March 31, 2020. The federal valuation allowance against tax credits in the amount of $0.9 million as of March 31, 2020 was released entirely as of March 31, 2021 due to sufficient taxable income available to utilize these credits. The Company had a valuation allowance of $28.5 million as of March 31, 2021 against deferred tax assets in the state of California, an increase from $27.7 million as of March 31, 2020 from activities during the year. The remaining valuation allowance primarily represents $0.4 million for various tax attribute carryforwards. The Company determined that it is more likely than not that the Company would not generate sufficient taxable income in the future to utilize such deferred tax assets.

As of March 31, 2021, the Company had foreign net operating loss and tax credit carryforwards for income tax purposes of $173.1 million and $67.5 million, respectively. Unused net operating loss carryforwards will expire at various dates in fiscal years 2021 to 2039. Certain net operating loss carryforwards in the United States relate to acquisitions and, as a result, are limited in the amount that can be utilized in any one year. The tax credit carryforwards will begin to expire in fiscal year 2022.

Swiss income taxes and non-Swiss withholding taxes associated with the repatriation of earnings or for other temporary differences related to investments in non-Swiss subsidiaries have not been provided for, as the Company intends to reinvest the earnings of such subsidiaries indefinitely. If these earnings were distributed to Switzerland in the form of dividends or otherwise, or if the shares of the relevant non-Swiss subsidiaries were sold or otherwise transferred, the Company may be subject to additional Swiss income taxes and non-Swiss withholding taxes. As of March 31, 2021, the cumulative amount of unremitted earnings of non-Swiss subsidiaries for which no income taxes have been provided is approximately $153.1 million. The amount of unrecognized deferred income tax liability related to these earnings is estimated to be approximately $2.1 million.

The Company follows a two-step approach in recognizing and measuring uncertain tax positions. The first step is to evaluate the tax position for recognition by determining if the weight of available evidence indicates that it is more likely than not that the position will be sustained on audit, including resolution of related appeals or litigation processes, if any. The second step is to measure the tax benefit as the largest amount that is more than 50% likely of being realized upon ultimate settlement.

As of March 31, 2021 and 2020, the total amount of unrecognized tax benefits due to uncertain tax positions was $160.3 million and $140.8 million, respectively, all of which would affect the effective income tax rate if recognized.

As of March 31, 2021 and 2020, the Company had $59.2 million and $40.8 million, respectively, in non-current income taxes payable, including interest and penalties, related to the Company's income tax liability for uncertain tax positions.


March 31, 2018	$	69,131
Lapse of statute of limitations	(2,511)
Decreases in balances related to tax positions taken during prior years	(1,550)
Increases in balances related to tax positions taken during the year	11,479
March 31, 2019	$	76,549
Lapse of statute of limitations	(3,501)
Decreases in balances related to tax positions taken during prior years	(679)
Increases in balances related to tax positions taken during the year	71,128
March 31, 2020	$	143,497
Lapse of statute of limitations	(4,024)
Decreases in balances related to tax positions taken during prior years	—
Increases in balances related to tax positions taken during the year	23,780
March 31, 2021	$	163,253

The Company recognizes interest and penalties related to unrecognized tax positions in income tax expense. The Company recognized $1.1 million, $2.0 million, and $0.6 million in interest and penalties in income tax expense during fiscal years 2021, 2020 and 2019, respectively. As of March 31, 2021 and 2020, the Company had $4.9 million, and $4.5 million, respectively, of accrued interest and penalties related to uncertain tax positions.

The Company files Swiss and foreign tax returns. The Company received final tax assessments in Switzerland through fiscal year 2018. For other foreign jurisdictions such as the United States, the Company is generally not subject to tax examinations for years prior to fiscal year 2018. The Company is under examination and has received assessment notices in foreign tax jurisdictions. If the examinations are resolved unfavorably, there is a possibility they may have a material negative impact on its results of operations.