It's kind of a joke though, isn't it? Like, Blizzard isn't doing any real work in Barbados or Bermuda. So you could probably argue it's wrong, unless you feel like arguing that all taxation is wrong from an Individualist perspective (which I'd be fine with).
And aside from wrong, the fact that they've agreed to pay a fine of $345 million means it was probably illegal. If they just phrased something wrong they could probably just correct the phrasing, and, more importantly, I think they probably tried really hard to get the phrasing right when transferring billions from one company to another.
I own offshore companies and minimize my tax burden, but let's call a spade a spade.
Choosing not to prosecute (especially because prosecuting tax fraud requires proof of willfulness) and simply collecting a tax deficit is pretty common, especially in cases of corporate tax evasion.
The disagreement in this case is called a tax deficit, and is what I meant by wrong. It's also the first necessary part of tax fraud.
EDIT: Also, if you read about the source of the $345 million tax bill (from the article), it's hard to see how this would've been a problem with "unclear phrasing"...
It all depends on the amounts being moved. Transfer pricing is complex because what is market rate in situation A is not market rate in situation B. $345 million could be a minor difference of a few percentage points on tens of billions in revenue.
Just like FDSGSG wrote above, I went through a sizeable tax dispute (for an individual, outside of the US) and won. I have a good understanding of tax law yet it was nothing more than a bullshit money grab. No merit, nothing. More along the line; that's a very nice outcome for you but we don't really like it -- so pay up regardless. Like trying to shake a tree.
In this case, I can imagine for Activision (as a publicly traded company) it is better to settle a case for an OK amount than take it to court and run through the process. You have to make a risk reward analysis of whether it's worth spending time and resources on.
Yes, obviously the settlement reflects analysis by Activision Blizzard, which is exactly the point. The expected outcome of challenging an assessed tax deficit is part of that analysis, so the choice to settle must be viewed with that in mind.
I wish both you and the thread OP would stop comparing this to A) personal (or small business) tax disputes and B) tax disputes that resulted in no additional tax liability. This dispute did result in additional tax liability.
At best it's indicative of bad accounting, but for a company like Activision Blizzard and at that amount that seems unlikely.