Income Taxes

9 Months Ended

Dec. 31, 2022

Income Tax Disclosure [Abstract]

Income Taxes

(9) INCOME TAXES

The provision for income taxes for the three and nine months ended December 31, 2022 is based on our projected annual effective tax rate for fiscal year 2023, adjusted for specific items that are required to be recognized in the period in which they are incurred. Our effective tax rate for the three and nine months ended December 31, 2022 was 28 percent and 29 percent, respectively, as compared to 27 percent and 22 percent, respectively, for the same period in fiscal year 2022. The rate for the nine months ended December 31, 2022 was higher than the same period in the prior year due to the Codemasters intra-entity sale of intellectual property rights to our U.S. and Swiss intellectual property owners completed during the nine months ended December 31, 2021, which resulted in a step-up of the U.S. and Swiss tax-deductible basis in the transferred intellectual property rights, and we recognized a $60 million net tax benefit for the current and deferred tax impacts of the sale. Excluding the Codemasters intra-entity sale, the effective tax rate for nine months ended December 31, 2021 would have been 30 percent.

We are subject to income tax examinations in various jurisdictions with respect to fiscal years after 2013. The timing and potential resolution of income tax examinations is highly uncertain. The gross unrecognized tax benefits as of December 31, 2022 were $788 million.

While we continue to measure our uncertain tax positions, the amounts ultimately paid, if any, upon resolution of the issues raised by the taxing authorities may differ materially from the amounts accrued. For example, in the period ended June 30, 2020, the decision of the Ninth Circuit Court of Appeals in Altera Corp. v Commissioner (“the Altera opinion”) resulted in a partial decrease of our unrecognized tax benefits. A complete resolution and settlement of the matters underlying the Altera opinion is reasonably possible within the next 12 months, which would result in an additional reduction of our gross unrecognized tax benefits. However, it is uncertain whether a complete resolution and settlement of such matters would also result in resolution of all related and unrelated U.S. positions for all applicable years. Therefore, it is not possible to provide a range of potential outcomes associated with a reversal of our gross unrecognized tax benefits. We expect changes in unrecognized tax benefits unrelated to the Altera opinion which may occur within the next twelve months to be insignificant.

On February 7, 2023, the Swiss Federal Tax Administration published an updated safe harbor interest rate, and we expect the higher rate to materially increase the valuation allowance against our Swiss deferred tax assets. We will recognize the impact to the income tax provision and the valuation allowance during the quarterly period ending March 31, 2023.