Net decrease in deferred tax asset valuation allowance for changes to foreign losses

  
Income tax related liabilities are included in the accompanying balance sheet as follows:

|  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
|  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
|  |  | As of |
| (in millions) |  | March 31, 2022 |  | March 31, 2021 |
| Current: |  |  |  |  |
| Liability for uncertain tax positions |  | $ | (34) |  |  | $ | (30) |  |
| Income taxes payable |  | (163) |  |  | (368) |  |
|  |  | $ | (197) |  |  | $ | (398) |  |
| Non-current: |  |  |  |  |
| Deferred taxes |  | (576) |  |  | (360) |  |
| Income taxes payable |  | (39) |  |  | (130) |  |
| Liability for uncertain tax positions |  | (379) |  |  | (364) |  |
|  |  | $ | (994) |  |  | $ | (854) |  |
|  |  |  |  |  |
| Total |  | $ | (1,191) |  |  | $ | (1,252) |  |

  
Significant management judgment is required in determining the Company's provision for income taxes, deferred tax assets and liabilities and any valuation allowance recorded against deferred tax assets. As of each reporting date, management weighs new evidence, both positive and negative, that could affect its view of the future realization of its net deferred tax assets. Objective verifiable evidence, which is historical in nature, carries more weight than subjective evidence, which is forward looking in nature.  
A valuation allowance has been recorded against deferred tax assets of approximately $2,133 million as of March 31, 2022 due to uncertainties related to the ability to utilize these assets. In assessing whether its deferred tax assets are realizable, the Company considers whether it is more likely than not that some portion or all of the deferred tax assets will not be realized and adjusts the valuation allowance accordingly. The Company considers all available positive and negative evidence including future reversals of existing taxable temporary differences, taxable income in prior carryback years, projected future taxable income, tax planning strategies and recent financial operations.  
In the current reporting period, the Company recorded adjustments to Luxembourg losses and corresponding adjustments to the valuation allowance. The net decrease in the valuation allowance of $1,729 million in fiscal 2022 is primarily due to changes in the Luxembourg losses of $1,609 million, other increases in the valuation allowance of $1 million and a currency translation adjustment of $121 million.101
