SEC Comment Letter for GSK (GSK) — Jun 2, 2015
GSK plc
Date: June 2, 2015 · CIK: 0001131399 · Accession: 0000000000-15-029205
AI Filing Summary & Sentiment
Letter
June 1, 2015 Via E -mail Mr. Simon Dingemans Chief Financial Officer GlaxoSmithKline plc 980 Great West Road Brentford Middlesex TW8 9GS United Kingdom
Re: GlaxoSmithKline plc Form 20-F for the Fiscal Year Ended December 31 , 2014 Filed February 27, 2015 File No. 1-15170
Dear Mr. Dingemans :
We have reviewed your May 6, 2015 response to our April 2, 2015 letter and have the following comment.
Please respond to this letter within 10 business days by providing the requested information or by advising us when you will provide the requested resp onse. If you do not believe the comment applies to your facts and circumstances, please tell us why in your response. Please furnish us a letter on EDGAR under the form type label CORRESP that keys your response to our comment.
After reviewing the information you provide, we may have additional comments and/or request that you amend your filing.
Exhibit 15.2: GSK Annual Report 2014 Notes to financial statements Note 14: Taxation, page 156
1. Please provide us proposed revised disclosure to be included in future periodic reports that explains the increase in tax rate associated with oversees operations and the decrease in tax rate associated with the benefit of intellectual property incentives consistent with your response to previous comment 1. In your disclosure, please identify the major tax jurisdictions involved and include a brief explanation of patent box regimes.
Mr. Simon Dingemans GlaxoSmithKline plc June 1, 2015 Page 2
You may contact Mark Brunhofer, Senior Staff Accountant , at (202) 551 -3638 or Lisa Vanjoske , Assistant Chief Account ant, at (202) 551 -3614 if you have questions regarding the comment s. In this regard, do not hesitate to contact me at (202) 551 -3679 .
Sincerely,
/s/ Jim B. Rosenberg
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June 1, 2015
Via E -mail
Mr. Simon Dingemans
Chief Financial Officer
GlaxoSmithKline plc
980 Great West Road
Brentford
Middlesex
TW8 9GS
United Kingdom
Re: GlaxoSmithKline plc
Form 20-F for the Fiscal Year Ended December 31 , 2014
Filed February 27, 2015
File No. 1-15170
Dear Mr. Dingemans :
We have reviewed your May 6, 2015 response to our April 2, 2015 letter and have the
following comment.
Please respond to this letter within 10 business days by providing the requested
information or by advising us when you will provide the requested resp onse. If you do not
believe the comment applies to your facts and circumstances, please tell us why in your
response. Please furnish us a letter on EDGAR under the form type label CORRESP that keys
your response to our comment.
After reviewing the information you provide, we may have additional comments and/or
request that you amend your filing.
Exhibit 15.2: GSK Annual Report 2014
Notes to financial statements
Note 14: Taxation, page 156
1. Please provide us proposed revised disclosure to be included in future periodic reports
that explains the increase in tax rate associated with oversees operations and the decrease
in tax rate associated with the benefit of intellectual property incentives consistent with
your response to previous comment 1. In your disclosure, please identify the major tax
jurisdictions involved and include a brief explanation of patent box regimes.
Mr. Simon Dingemans
GlaxoSmithKline plc
June 1, 2015
Page 2
You may contact Mark Brunhofer, Senior Staff Accountant , at (202) 551 -3638 or Lisa
Vanjoske , Assistant Chief Account ant, at (202) 551 -3614 if you have questions regarding the
comment s. In this regard, do not hesitate to contact me at (202) 551 -3679 .
Sincerely,
/s/ Jim B. Rosenberg
Jim B. Rosenberg
Senior Assistant Chief Accountant