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Income taxes
12 Months Ended
Mar. 31, 2016
Income taxes  
Income taxes

15. Income taxes:

The following table presents components of Income tax expense reported in the consolidated statements of income for the years ended March 31, 2014, 2015 and 2016.

 

     Millions of yen  
     Year ended March 31  
     2014      2015      2016  

Current:

        

Domestic

   ¥ 21,558       ¥ 80,760       ¥ 72,272   

Foreign

     6,546         13,531         9,183   
  

 

 

    

 

 

    

 

 

 

Subtotal

     28,104         94,291         81,455   
  

 

 

    

 

 

    

 

 

 

Deferred:

        

Domestic

     109,037         23,309         (66,176

Foreign

     8,024         3,180         7,317   
  

 

 

    

 

 

    

 

 

 

Subtotal

     117,061         26,489         (58,859
  

 

 

    

 

 

    

 

 

 

Total

   ¥ 145,165       ¥ 120,780       ¥ 22,596   
  

 

 

    

 

 

    

 

 

 

 

The income tax benefit recognized from operating losses for the years ended March 31, 2014, 2015 and 2016 was ¥26,990 million, ¥3,888 million and ¥5,451 million, respectively, included within deferred income tax expense above.

The Company and its wholly-owned domestic subsidiaries have adopted the consolidated tax filing system permitted under Japanese tax law. The consolidated tax filing system is permitted only for a national tax.

As a result of revisions to domestic tax laws during the third quarter ended December 31, 2011, the fourth quarter ended March 31, 2014 and 2015, Nomura’s domestic effective statutory tax rate was approximately 38% for the fiscal year ended March 31, 2014, decreased to approximately 36% for the fiscal year ended March 31, 2015, and decreased to approximately 33% for the fiscal year ended March 31, 2016.

On March 29, 2016, the “Act to partially revise the Income Tax Act and Others” (Act No.15 of 2016) (“Act 15”) and “Act to partially revise the Local Tax Act and Others” (Act No.13 of 2016) (“Act 13”) were enacted. Under Act 13 and Act 15, effective from the fiscal year beginning on or after April 1, 2016, corporate tax rate has been reduced from 32% to 31% for the temporary differences expected to be reversed in the fiscal year beginning on or after April 1, 2016. Use of operating loss carryforwards for the tax purposes will be limited to 60% of the current year taxable income before deducting operating loss carryforwards for tax purpose after the fiscal years beginning on or after April 1, 2016, and 55% after the fiscal years beginning on or after April 1, 2017. The fiscal years beginning on or after April 1, 2018, use of operating loss carryforwards for the tax purposes will continue to be limited to 50%. Due to these revisions, net deferred tax liabilities decreased by ¥1,525 million yen and income tax expenses decreased by the same amount.

Foreign subsidiaries are subject to income taxes of the countries in which they operate. The relationship between income tax expense and pretax accounting income (loss) is affected by a number of items, including various tax credits, certain revenues not subject to income taxes, certain expenses not deductible for income tax purposes, changes in deferred tax valuation allowance and different enacted tax rates applicable to foreign subsidiaries.

The following table presents a reconciliation of the effective income tax rate reflected in the consolidated statements of income to Nomura’s effective statutory tax rate for the years ended March 31, 2014, 2015 and 2016.

 

     Year ended March 31  
         2014             2015             2016      

Nomura’s effective statutory tax rate

     38.0     36.0     33.0

Impact of:

      

Changes in deferred tax valuation allowance

     (9.8     5.1        36.1   

Additional taxable revenues

     0.4        0.3        0.3   

Non-deductible expenses

     7.7        5.9        7.8   

Non-taxable revenue

     (8.0     (4.7     (7.2

Dividends from foreign subsidiaries

     —          0.0        0.0   

Tax effect of undistributed earnings of foreign subsidiaries

     3.5        0.0        0.1   

Different tax rate applicable to income (loss) of foreign subsidiaries

     6.3        (1.4     1.1   

Effect of changes in domestic tax laws

     0.6        (1.4     (0.9

Expiration of loss carryforwards

     0.7        0.0        —     

Tax benefit recognized on the devaluation of investment in subsidiaries and affiliates

     1.4        —          (54.8

Other

     (0.7     (5.0     (1.8
  

 

 

   

 

 

   

 

 

 

Effective tax rate

     40.1     34.8     13.7
  

 

 

   

 

 

   

 

 

 

 

The following table presents the significant components of deferred tax assets and liabilities as of March 31, 2015 and 2016, before offsetting of amounts which relate to the same tax-paying component within a particular tax jurisdiction.

 

     Millions of yen  
     March 31  
     2015     2016  

Deferred tax assets

    

Depreciation, amortization and valuation of fixed assets

   ¥ 14,692      ¥ 16,862   

Investments in subsidiaries and affiliates

     33,553        112,030   

Valuation of financial instruments

     56,566        60,776   

Accrued pension and severance costs

     10,335        16,190   

Other accrued expenses and provisions

     123,567        96,202   

Operating losses

     466,531        435,122   

Other

     4,356        5,644   
  

 

 

   

 

 

 

Gross deferred tax assets

     709,600        742,826   

Less—Valuation allowance

     (565,103     (543,489
  

 

 

   

 

 

 

Total deferred tax assets

     144,497        199,337   
  

 

 

   

 

 

 

Deferred tax liabilities

    

Investments in subsidiaries and affiliates

     109,087        121,874   

Valuation of financial instruments

     56,808        49,873   

Undistributed earnings of foreign subsidiaries

     735        711   

Valuation of fixed assets

     20,644        19,165   

Other

     8,670        6,822   
  

 

 

   

 

 

 

Total deferred tax liabilities

     195,944        198,445   
  

 

 

   

 

 

 

Net deferred tax assets (liabilities)

   ¥ (51,447   ¥ 892   
  

 

 

   

 

 

 

After offsetting deferred tax assets and liabilities which relate to the same tax-paying component within a particular tax jurisdiction, net deferred tax assets reported within Other assets—Other in the consolidated balance sheets were ¥19,718 million and ¥36,130 million as of March 31, 2015 and 2016, respectively and net deferred tax liabilities reported within Other liabilities in the consolidated balance sheets were ¥71,165 million and ¥35,238 million as of March 31, 2015 and 2016, respectively.

As of March 31, 2016, no deferred tax liabilities have been recognized for undistributed earnings of foreign subsidiaries totaling ¥10,649 million which are not expected to be remitted in the foreseeable future. It is not practicable to determine the amount of income taxes payable in the event all such foreign earnings are repatriated.

 

The following table presents changes in the total valuation allowance established against deferred tax assets for the years ended March 31, 2014, 2015 and 2016.

 

     Millions of yen  
     Year ended March 31  
     2014     2015      2016  

Balance at beginning of year

   ¥ 522,220      ¥ 490,603       ¥ 565,103   

Net change during the year

     (31,617 )(1)      74,500 (2)        (21,614 )(3) 
  

 

 

   

 

 

    

 

 

 

Balance at end of year

     490,603        565,103         543,489   
  

 

 

   

 

 

    

 

 

 

 

(1) Primarily includes ¥29,134 million of additional full valuation allowances established by certain foreign subsidiaries against additional operating loss carryforwards generated during the period as a result of additional taxable losses being incurred by such subsidiaries, offset by a reduction of ¥47,263 million of valuation allowances related to the liquidation of certain foreign subsidiaries and a reduction of ¥13,488 million of valuation allowances established by the Company and domestic subsidiaries because of changes in the expected realization of deferred tax assets other than those related to operating loss carryforwards. In total, ¥31,617 million of allowances decreased for the year ended March 31, 2014.
(2) Primarily includes ¥85,403 million of additional full valuation allowances established by certain foreign subsidiaries against additional operating loss carryforwards generated during the period as a result of additional taxable losses being incurred by such subsidiaries, offset by a reduction of ¥2,921 million of valuation allowances of certain foreign subsidiaries and a reduction of ¥7,982 million related to Japanese subsidiaries and the Company because of decrease in valuation allowances related to operating loss carryforwards due to the effect of changes in domestic tax laws. In total, ¥74,500 million of allowances increased for the year ended March 31, 2015.
(3) Primarily includes ¥7,003 million of additional full valuation allowances established by certain foreign subsidiaries against additional operating loss carryforwards generated during the period as a result of additional taxable losses being incurred by such subsidiaries, offset by a reduction of ¥27,757 million of valuation allowances of certain foreign subsidiaries and a reduction of ¥860 million related to Japanese subsidiaries and the Company because of decrease in valuation allowances related to operating loss carryforwards due to the effect of changes in domestic tax laws. In total, ¥21,614 million of allowances decreased for the year ended March 31, 2016.

As of March 31, 2016, total operating loss carryforwards were ¥2,127,536 million, which included ¥602,036 million relating to the Company and domestic subsidiaries, ¥721,069 million relating to foreign subsidiaries in the United Kingdom, ¥511,732 million relating to foreign subsidiaries in the United States, ¥217,337 million relating to foreign subsidiaries in Hong Kong, and ¥75,362 million relating to foreign subsidiaries in other tax jurisdictions. Of this total amount, ¥1,009,812 million can be carried forward indefinitely, ¥769,789 million expires by March 31, 2025 and ¥347,935 million expires in later fiscal years.

In determining the amount of valuation allowances to be established as of March 31, 2016, Nomura considered all available positive and negative evidence around the likelihood that sufficient future taxable income will be generated to realize the deferred tax assets in the relevant tax jurisdiction of the Company, its domestic subsidiaries and foreign subsidiaries.

In Japan and other tax jurisdictions where domestic and foreign subsidiaries have experienced cumulative operating losses in recent years, these losses provided the most verifiable negative evidence available and outweigh positive evidence.

 

While Nomura has considered certain future tax planning strategies as a potential source of future taxable income, no such strategies have been relied upon as positive evidence resulting in the reduction of valuation allowances in any major tax jurisdiction in which Nomura operates as of March 31, 2014, 2015 and 2016. In addition, valuation allowances have not been reduced in any of these periods as a result of changing the weighting applied to positive or negative evidence in any of the major tax jurisdictions in which Nomura operates.

The total amount of unrecognized tax benefits was not significant as of March 31, 2014, 2015 and 2016. There were also no significant movements of the gross amounts in unrecognized tax benefits and the amount of interest and penalties recognized due to the unrecognized tax benefits during the years ended March 31, 2014, 2015 and 2016. Nomura is under continuous examination by the Japanese National Tax Agency and other taxing authorities in the major jurisdictions in which Nomura operates. Nomura regularly assesses the likelihood of additional assessments in each tax jurisdiction and the impact on these consolidated financial statements. It is reasonably possible that there may be a significant increase in unrecognized tax benefits within 12 months of March 31, 2016. Quantification of an estimated range cannot be made at this time due to the uncertainty of the potential outcomes. However, Nomura does not expect that any change in the gross balance of unrecognized tax benefits would have a material effect on its financial condition.

Nomura operates in multiple tax jurisdictions, and faces audits from various taxing authorities regarding many issues including, but not limited to, transfer pricing, the deductibility of certain expenses, foreign tax credits and other matters.

The table below presents information regarding the earliest year in which Nomura remains subject to examination in the major jurisdictions in which Nomura operates as of March 31, 2016. Under Hong Kong Special Administrative Region (“Hong Kong”) tax law, the statute of limitation does not apply if an entity incurs taxable losses and is therefore not included in the table.

 

Jurisdiction

   Year  

Japan

     2011 (1) 

United Kingdom

     2014   

United States

     2013   

 

(1) The earliest year in which Nomura remains subject to examination for transfer pricing issues is 2010.