XML 30 R16.htm IDEA: XBRL DOCUMENT v3.25.1
Income Taxes
 12 Months Ended
Mar. 31, 2025
Income Tax Disclosure [Abstract]  
Income Taxes Income Taxes
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 before taxes and the provision for income taxes is generated outside of Switzerland.
Income from continuing operations before income taxes for fiscal years 2025, 2024 and 2023 is summarized as follows (in thousands):
 Years Ended March 31,
 202520242023
Swiss$492,941 $502,291 $282,970 
Non-Swiss213,931 119,305 180,552 
Income before taxes$706,872 $621,596 $463,522 
The provision for income taxes is summarized as follows (in thousands):
Years Ended March 31,
202520242023
Current:
Swiss$(14,673)$26,833 $19,405 
Non-Swiss33,473 25,044 48,829 
Deferred:
Swiss45,283 (47,517)26,629 
Non-Swiss11,260 5,093 4,085 
Provision for income taxes$75,343 $9,453 $98,947 
The difference between the provision for income taxes and the expected tax provision at the Swiss statutory income tax rate of 8.5% is reconciled below (in thousands):
 Years Ended March 31,
 202520242023
Expected tax provision at statutory income tax rates$60,084 $52,836 $39,399 
Income taxes at different rates68,212 47,595 38,467 
Research and development tax credits(6,797)(9,738)(152)
Swiss Tax Benefits
— (50,051)— 
Executive compensation980 407 749 
Stock-based compensation(2,162)4,019 5,736 
Deferred tax effects from TRAF— (33,926)— 
Valuation allowance1,000 4,780 908 
Impairment— — 1,881 
Restructuring credits
(817)— (1,764)
Unrecognized tax benefits/ Audit resolution and statute lapse
(43,333)11,535 13,284 
FDII deduction(1,424)(18,675)— 
Other, net(400)671 439 
Provision for income taxes$75,343 $9,453 $98,947 
The effective income tax rate in 2025 includes the tax effect of audit resolutions and the expiration of statutes of limitation of uncertain tax positions totaling $53.3 million, offset by the increase to unrecognized tax benefits in 2025 of $10.0 million. The effective tax rate in 2024 includes the discrete tax benefits recognized in fiscal year 2024 for the benefit of future Swiss tax deductions, the remeasurement of the tax basis of goodwill under TRAF (as defined below), FDII (as defined below) incentive provided by the Tax Cuts and Jobs Act and remeasurement of our Swiss deferred tax assets due to a change in tax rate.
On March 28, 2024, the Swiss canton of Vaud confirmed a future tax benefit to be recognized for ten years. This resulted in the Company recording an income tax benefit of $50.1 million during the fiscal year ended March 31, 2024, which will be utilized over a ten-year period.
The canton of Vaud completed the legislative process to enact the Swiss Federal Act on Tax Reform and AHV Financing (“TRAF”), a reform to better align the Swiss tax system to international tax standards on March 20, 2020 that took effect as of January 1, 2020. In March 2020, the Company increased the tax basis of goodwill, as a transition measure under TRAF, to be amortized over ten years beginning on January 1, 2020. During the fiscal year ended March 31, 2024, the Company remeasured the tax basis of goodwill under TRAF, which resulted in an income tax benefit of $25.1 million, net of assessment for uncertain tax positions. The remeasurement of the step-up will be amortized over the remaining ten-year amortization period.
The Tax Cuts and Jobs Act enacted Section 250, which provides for a deduction with respect to Global Intangible Low-Taxed Income ("GILTI") and Foreign-Derived Intangible Income ("FDII") in the US. The application of this tax incentive is inherently complex. During the fiscal year ended March 31, 2024, the Company analyzed the applicability of FDII and determined that this tax incentive applies to fiscal years 2021, 2022 and 2023. As a result, the Company realized a tax benefit of $18.7 million related to FDII. The Company has also concluded that any GILTI tax since the enactment of Tax Cuts and Jobs Act is immaterial.
On December 29, 2023, a change to the cantonal tax legislation was published. According to the law approved by the Vaud parliament, a progressive scale will be applicable for cantonal tax purposes resulting in an increase from the then current tax rate of 13.61% to 14.28% effective fiscal year 2025. The increase in tax rate resulted in a tax benefit of $5.1 million due to a remeasurement of the Company's Swiss deferred tax assets in the fiscal year ended March 31, 2024.
The Base Erosion and Profit Shifting Project (the “BEPS Project”) undertaken by the Organization for Economic Co-operation and Development (the “OECD”) recommended changes to numerous long-standing tax principles, including a proposal to reallocate profits among tax jurisdictions in which companies do business (“Pillar One”) and establishing a minimum tax on global income (“Pillar Two”).
For the year ended March 31, 2025, the Company assessed its exposure to the OECD Pillar Two global minimum tax rules. The Company has determined that, for the fiscal year 2025, certain jurisdictions in which it operates should qualify for the transitional Country-by-Country Reporting ("CbCR") safe harbor, as outlined in the OECD Administrative Guidance and enacted domestic legislation.
The Company's CbCR has been prepared in accordance with the requirements for a Qualified CbCR, using qualified financial statements, and has been reviewed to ensure accuracy and completeness. Based on this data, the Company met safe harbor qualifications and therefore is not required to perform a detailed Pillar Two top-up tax calculation for the current reporting period. No Pillar Two top-up tax expense has been recognized in the year ended March 31, 2025. The OECD and participating countries continue to issue underlying rules and administrative guidance related to Pillar Two, and the Company continues to monitor the relevant developments.
Deferred income tax assets and liabilities consist of the following (in thousands):
 March 31,
 20252024
Deferred tax assets:  
Tax attributes carryforward$43,536 $43,846 
Future tax deduction from Swiss Tax Benefits48,267 49,755 
Accruals72,114 77,302 
Tax step-up of goodwill from TRAF86,519 105,942 
Share-based compensation15,411 13,718 
Gross deferred tax assets265,847 290,563 
Valuation allowance(36,537)(35,536)
Deferred tax assets after valuation allowance229,310 255,027 
Deferred tax liabilities:  
Acquired intangible assets and other(27,788)(30,901)
Deferred tax liabilities(27,788)(30,901)
Deferred tax assets, net$201,522 $224,126 
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 $36.5 million at March 31, 2025, compared to $35.5 million at March 31, 2024. The Company had a valuation allowance of $36.4 million as of March 31, 2025 against deferred tax assets in the state of California, an increase from $35.3 million as of March 31, 2024 from activities during the year. 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, 2025, the Company had net operating loss carryforwards in Switzerland for income tax purposes of $36.7 million which will begin to expire in fiscal year 2028. The Company had net operating loss and tax credit carryforwards in the United States for income tax purposes of $2.3 million and $76.0 million, respectively, as of March 31, 2025. The 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 and have no expiration. The tax credit carryforwards will begin to expire in fiscal year 2026.
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, 2025, the cumulative amount of unremitted earnings of non-Swiss subsidiaries for which no income taxes have been provided is approximately $546.9 million. The amount of unrecognized deferred income tax liability related to these earnings is estimated to be approximately $18.4 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, 2025 and 2024, the total amount of unrecognized tax benefits due to uncertain tax positions was $152.0 million and $192.7 million, respectively, all of which would affect the effective income tax rate if recognized.
As of March 31, 2025 and 2024, the Company had $88.5 million and $112.6 million, respectively, in non-current income taxes payable, including interest and penalties, related to the Company's income tax liability for uncertain tax positions.
The aggregate changes in gross unrecognized tax benefits in fiscal years 2025, 2024 and 2023 were as follows (in thousands):
March 31, 2022$179,372 
Lapse of statute of limitations(3,586)
Increases in balances related to tax positions taken during the year15,214 
March 31, 2023$191,000 
Lapse of statute of limitations(3,863)
Settlements with taxing authorities41 
Increases in balances related to tax positions taken during prior years
705 
Increases in balances related to tax positions taken during the year$22,332 
March 31, 2024$210,215 
Lapse of statute of limitations(25,075)
Settlements with taxing authorities(32,314)
Increases (decreases) in balances related to tax positions taken during prior years
(3,055)
Increases in balances related to tax positions taken during the year2,213 
March 31, 2025$151,984 
The Company recognizes interest and penalties related to unrecognized tax positions as income tax expense. The Company recognized $(0.6) million and $1.7 million, in interest and penalties related to unrecognized tax positions in income tax expense during fiscal years 2025 and 2024, respectively. In 2025, the interest accrual was reduced in excess of the current year accrual build as a result of audit settlements and statute lapses. As of March 31, 2025 and 2024, the Company had $7.2 million, and $7.8 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 2023. As a result of these audit settlements the Company released $31.8 million of previously recorded unrecognized tax benefits which was fully recognized as a reduction of income tax expense in the year ended March 31, 2025. In the United States, the federal and state tax agencies have the authority to examine periods prior to fiscal year 2021, to the extent allowed by law, but only to the extent tax attributes were generated, carried forward, and are being utilized in subsequent years. The statute of limitations in the United States otherwise lapsed for fiscal year 2021 in fiscal year 2025. The Company is under examination in several foreign tax jurisdictions. If the examinations are resolved unfavorably, there is a possibility they may have a negative impact on its results of operations.
Although the Company has adequately provided for uncertain tax positions, the provisions on these positions may change as revised estimates are made or the underlying matters are settled or otherwise resolved. During the next 12 months, it is reasonably possible that the amount of unrecognized tax benefits could increase or decrease significantly due to changes in tax law in various jurisdictions, due to lapse in statute of limitations and other factors, it is not possible to provide a range of potential changes.