in EUR m | 2025 | 2024 | 2023 |
Current income tax charge | (40.6) | (43.8) | (26.8) |
Deferred tax credit | 11.2 | 30.0 | 25.8 |
Total | (29.4) | (13.8) | (1.0) |
Reconciliation of tax expense | |||
in EUR m | 2025 | 2024 | 2023 |
Loss before tax | (75.8) | (11.0) | (149.1) |
Tax at Swiss tax rate | 13.9 | 2.0 | 27.4 |
+ / - effects of | |||
Deviations from Swiss tax rate | 6.7 | 2.1 | 15.0 |
Unrecognized deferred tax assets | (29.6) | 8.7 | (28.7) |
Deferred taxes related to other periods | (2.8) | 6.7 | 3.7 |
Change in deferred tax due to tax rate change | 1.0 | (0.3) | (0.6) |
Non-deductible expenses | (30.3) | (32.3) | (20.2) |
Income not subject to tax | 3.9 | 1.6 | 7.1 |
Current taxes related to other periods or other countries | 6.0 | (1.6) | (4.0) |
Others(I) | 1.8 | (0.7) | (0.7) |
Total tax expense | (29.4) | (13.8) | (1.0) |
Weighted average effective tax rate | (38.8%) | (125.5%) | (0.7%) |
(I) Others include predominantly foreign exchange adjustments and tax risk provisions
The above table shows the expected tax expense at the Swiss tax rate of 18.4% (2024 and 2023: 18.4%) applied to the Group loss before tax and the reconciliation to the actual income tax expense.
in EUR m | 2025 | 2024 | 2023 |
Deferred income tax assets | 61.0 | 48.2 | 33.4 |
Deferred income tax liabilities | (21.2) | (20.7) | (36.0) |
Balance at December 31 | 39.8 | 27.5 | (2.6) |
Movements in deferred taxes | ||||||
in EUR m | Property, plant and equipment | Intangible assets | Other assets | Liabilities(I) | Tax losses carry forwards | Total |
Balance at January 1, 2025 | (88.7) | (58.6) | (23.0) | 134.5 | 63.3 | 27.5 |
Deferred tax credit/(charge) in the income statement | (7.2) | 16.8 | (19.5) | 36.2 | (15.1) | 11.2 |
Deferred tax credit in OCI | - | - | - | 3.6 | - | 3.6 |
Exchange differences | 5.6 | (0.3) | 0.1 | (8.5) | 0.6 | (2.5) |
Balance at December 31, 2025 | (90.3) | (42.1) | (42.4) | 165.8 | 48.8 | 39.8 |
Balance at January 1, 2024 | (74.7) | (55.8) | (25.6) | 92.5 | 61.0 | (2.6) |
Deferred tax credit/(charge) in the income statement | (11.8) | (2.9) | 3.0 | 40.5 | 1.2 | 30.0 |
Deferred tax charge in OCI | - | - | - | (0.1) | - | (0.1) |
Exchange differences | (2.2) | 0.1 | (0.4) | 1.6 | 1.1 | 0.2 |
Balance at December 31, 2024 | (88.7) | (58.6) | (23.0) | 134.5 | 63.3 | 27.5 |
Balance at January 1, 2023 | (83.5) | (58.8) | (34.0) | 104.6 | 43.8 | (27.9) |
Deferred tax credit/(charge) in the income statement | 8.0 | 4.6 | 9.3 | (11.7) | 15.6 | 25.8 |
Deferred tax credit in OCI | - | - | - | 1.1 | - | 1.1 |
Exchange differences | 0.8 | (1.6) | (0.9) | (1.5) | 1.6 | (1.6) |
Balance at December 31, 2023 | (74.7) | (55.8) | (25.6) | 92.5 | 61.0 | (2.6) |
In 2025, EUR 3.6m of the deferred tax credit recognized in the OCI relates to actuarial gains and losses on defined benefit schemes (2024: deferred tax charge of EUR 0.1m; 2023: deferred tax credit of EUR 1.1m).
Composition of deferred tax assets and liabilities | |||||||||
in EUR m | Assets December 31 | Liabilities December 31 | Net December 31 | ||||||
2025 | 2024 | 2023 | 2025 | 2024 | 2023 | 2025 | 2024 | 2023 | |
Temporary differences | |||||||||
Property, plant and equipment | 5.0 | 5.0 | 5.5 | (95.3) | (93.7) | (80.2) | (90.3) | (88.7) | (74.7) |
Intangible assets | 0.9 | 0.5 | 7.0 | (43.0) | (59.1) | (62.8) | (42.1) | (58.6) | (55.8) |
Other assets | 11.6 | 8.0 | 9.7 | (54.0) | (31.0) | (35.3) | (42.4) | (23.0) | (25.6) |
Retirement benefit obligations, other liabilities, provisions and accruals | 191.3 | 158.4 | 118.3 | (25.5) | (23.9) | (25.8) | 165.8 | 134.5 | 92.5 |
Tax losses | 48.8 | 63.3 | 61.0 | - | - | - | 48.8 | 63.3 | 61.0 |
257.6 | 235.2 | 201.5 | (217.8) | (207.7) | (204.1) | 39.8 | 27.5 | (2.6) | |
Offset of deferred tax assets and liabilities | (196.6) | (187.0) | (168.1) | 196.6 | 187.0 | 168.1 | - | - | - |
Deferred tax assets/(liabilities) | 61.0 | 48.2 | 33.4 | (21.2) | (20.7) | (36.0) | 39.8 | 27.5 | (2.6) |
Composition of deferred tax assets not recognized | |||
in EUR m | 2025 | 2024 | 2023 |
Property, plant and equipment | 3.4 | 4.8 | 5.0 |
Intangible assets | 0.1 | 0.2 | 1.4 |
Other assets | 2.3 | 5.3 | 8.7 |
Retirement benefit obligations, other liabilities, provisions and accruals | 27.3 | 50.1 | 89.1 |
Tax losses | 438.1 | 456.8 | 477.9 |
Deferred tax assets not recognized at 31 December | 471.2 | 517.2 | 582.1 |
The Group does not regard any retained earnings of foreign subsidiaries as permanently invested and does not expect any material additional tax payables beyond the recognized deferred tax liabilities on unremitted earnings of the Group.
Tax loss carry forwards and tax credits which are not recognized are summarized by year of expiry as follows:
in EUR m | 2025 | 2024 | 2023 |
Less than one year | 53.3 | 11.2 | 8.9 |
More than one year and less than five years | 504.2 | 524.2 | 612.8 |
More than five years | 236.2 | 365.0 | 340.3 |
No expiry | 1,149.1 | 1,009.6 | 1,104.8 |
Total | 1,942.8 | 1,910.0 | 2,066.8 |
Tax loss carry forwards which are not recognized are summarized by country of origin as follows: | |||
in EUR m | 2025 | 2024 | 2023 |
Switzerland | 684.6 | 661.6 | 848.2 |
Luxembourg | 354.8 | 310.3 | 367.3 |
Germany | 351.9 | 403.4 | 318.6 |
France | 112.7 | 106.3 | 101.6 |
United Kingdom | 115.8 | 99.2 | 65.4 |
Brazil | 61.8 | 54.8 | 58.2 |
Denmark | 35.0 | 43.5 | 45.2 |
US | 38.7 | 40.5 | 45.4 |
Norway | 39.0 | 38.9 | 38.1 |
Singapore | 27.9 | 29.9 | 28.8 |
Belgium | 21.0 | 22.2 | 24.1 |
Italy | 17.6 | 18.7 | 14.8 |
Others | 82.0 | 80.7 | 111.1 |
Total | 1,942.8 | 1,910.0 | 2,066.8 |
There are no significant unrecognized tax credits.
The Group is within the scope of the Organization for Economic Co-operation and Development (“OECD”) Pillar Two model rules. The Group operates in several jurisdictions where Pillar Two Rules have been enacted, or substantively enacted. In Switzerland, the jurisdiction in which the Company is tax-resident, a gradual implementation of Pillar Two took place with the introduction of a Qualified Domestic Minimum Top-up Tax (“QDMTT”) effective from January 1, 2024, and the Income Inclusion Rule (“IIR”) effective from January 1, 2025. The latter rule requires Switzerland to levy taxes on Pillar Two-qualifying profits not only in Switzerland but of subsidiaries in other jurisdictions not reaching the 15% minimum rate. The Federal Council has decided not to bring the Undertaxed Profits Rule (“UTPR”) into force for the time being. The Group makes use of the Transitional Country-by-Country Reporting Safe Harbor under which the Top-up tax in a jurisdiction shall be deemed to be zero if that jurisdiction passes at least one out of three Transitional Safe Harbor tests. The Group applies the mandatory exception, as provided in the amendments to IAS 12 Income Taxes, to recognizing and disclosing information about deferred tax assets and liabilities related to Pillar Two income taxes.
Under the Pillar Two Rules, the Group is liable to pay a Top-up tax for the difference between its Global Anti-Base Erosion ("GloBE") effective tax rate per jurisdiction and the 15% minimum tax rate under the IIR or QDMTT. The Group operates in some jurisdictions with a nominal tax rate below 15%, however, the Group might not be exposed to paying a material amount of Pillar Two income taxes due to the application of specific adjustments to the calculation of the Jurisdictional Top-up Tax Percentage envisaged in the Pillar Two Rules. In 2025, the Group identified several jurisdictions that cannot benefit from Pillar Two Transitional Safe Harbour rules. Those jurisdictions are required to undertake full GloBE computation. However, based on the assessment to date, the Group is not expected to have a material impact in 2025 resulting from Pillar Two. The IIR or QDMTT is also not expected to have a material impact in 2026.
The Group keeps closely monitoring Pillar Two developments and potential impact to the Group.
Income tax expense in the Consolidated Income Statement is comprised of current and deferred income taxes. Transactions recognized in OCI include any related tax effects. Current income tax is the expected tax payable on the taxable income for the year, using tax rates enacted or substantively enacted at the balance sheet date together with any adjustments to tax payable in respect of previous years.
Deferred income tax is recognized based on the balance sheet liability method, which measures temporary differences between the carrying amounts of assets and liabilities for financial reporting purposes and the amounts used for taxation purposes. The amount of deferred income tax recognized is based on the expected manner of realization or settlement of the carrying amount of assets and liabilities, using tax rates enacted or substantively enacted at the balance sheet date. A deferred income tax asset is recognized to the extent that it is probable that future taxable profits will be available against which the asset can be utilized. At each balance sheet date, the Group assesses the recoverability of its deferred income tax assets. Deferred income tax is provided on temporary differences arising on investments in subsidiaries and associates, except where the timing of the reversal is controlled by the Group and it is probable that the temporary difference will not reverse in the foreseeable future. Deferred income tax assets and liabilities are offset only when the Group has a legally enforceable right to offset.
Provisions for income taxes require significant judgment as these are based on transactions and calculations for which the ultimate tax determination is spread over numerous jurisdictions. Deferred tax assets are based on anticipated results for the relevant taxable entity over a period of several years into the future, including interpretations of existing tax laws and regulations.