NEW YORK (S&P Global Ratings) Nov. 4, 2020--Ireland-headquartered Perrigo Co. PLC (BBB-/Stable/--) announced that the Irish High Court ruled against its request and stated Irish Revenue's €1.636 billion ($1.918 billion) amended tax assessment did not violate the company's legitimate expectations. This setback means Perrigo will now have to either appeal this ruling or appeal the actual merits of the assessment with the Tax Appeals Commission. We believe the appeals process will be lengthy (likely more than two years) and view the outcome as highly uncertain. Therefore, we do not currently incorporate the estimated cash outflow for the assessment into our adjusted metrics but do qualitatively consider the potential liability in our analysis. We believe Perrigo has capacity for about $1