13. Deferred tax assets and liabilities

Deferred tax is provided in full, using the liability method, on the temporary differences arising between the tax bases of assets and liabilities and their carrying amounts in the consolidated financial statements. But the deferred tax is not accounted for if it arises from initial recognition of an asset or a liability in a transaction other than a business combination that at the time of the transaction affects neither the accounting nor taxable income statement. Deferred tax is determined using tax rates (and laws) that have been enacted or substantially enacted by the balance sheet date and are expected to apply when the related deferred tax asset is realised, or the deferred tax liability is settled.

Deferred tax assets are recognised to the extent that it is probable that future taxable profit will be available against which the temporary differences can be utilised.

Deferred tax is provided on temporary differences arising on investments in subsidiaries, except where the timing of the reversal of the temporary difference is controlled by TMF Group and it is probable that the temporary difference will not be reversed in the foreseeable future.

Deferred tax assets and deferred tax liabilities are offset to the extent that an entity has a legally enforceable right to set off current tax assets against current tax liabilities and are levied by same taxation authority.

In millions of Euro

31 December 2024

31 December 2023

Deferred tax assets

80.5

80.2

Netting DTA/DTL

(80.5)

(80.2)

Deferred tax asset

-

-

Deferred tax liabilities

(321.3)

(318.4)

Netting DTA/DTL

80.5

80.2

Deferred tax liability (net)

(240.8)

(238.2)

The gross movement in the deferred tax account is as follows:

In millions of Euro

31 December 2024

31 December 2023

Beginning of the year

(238.2)

-

Acquired through business combinations (note 15)

0.2

(247.3)

Additions (note 15)

(11.2)

-

Exchange differences

0.6

(0.9)

Recorded in profit or loss

7.8

10.0

End of the year

(240.8)

(238.2)

The movement in deferred tax assets and liabilities during the year is as follows:

Deferred tax assets

In millions of Euro

Intangible assets

Tax losses

Provisions

Property, plant and equipment

Right of use asset

Other

Netting

Total

At 1 January 2023

-

-

-

-

-

-

-

-

Acquired through business combinations

47.7

26.3

2.4

0.8

-

5.3

(59.0)

23.5

Charge/(credit) to the income statement

-

(3.8)

(1.8)

2.4

1.1

(0.2)

-

(2.3)

Exchange differences

-

-

-

-

-

-

-

-

Netting DTA/DTL

-

-

-

-

-

-

(21.2)

(21.2)

At 31 December 2024

47.7

22.5

0.6

3.2

1.1

5.1

(80.2)

-

At 1 January 2024

47.7

22.5

0.6

3.2

1.1

5.1

(80.2)

-

Acquired through business combinations

-

-

-

-

-

0.2

-

0.2

Additions

-

-

-

-

-

-

-

-

Charge/(credit) to the income statement

(4.9)

3.8

0.1

0.8

0.5

-

-

0.4

Exchange differences

-

-

-

-

-

(0.3)

-

(0.3)

Netting DTA/DTL

-

-

-

-

-

-

(0.3)

(0.3)

At 31 December 2024

42.8

26.3

0.7

4.0

1.6

5.0

(80.5)

(0.0)

Deferred tax liabilities

In millions of Euro

Intangible assets

Provisions

Property, plant and equipment

Right of use asset

Other

DTA/DTL

Netting

Total

At 1 January 2023

-

-

-

-

-

-

-

-

Acquired through business combinations

320.0

1.7

0.4

-

4.7

-

(59.0)

267.8

Charge / credited to the income statement

(9.2)

(1.2)

-

0.1

2.8

-

-

(7.5)

Exchange differences

-

-

-

-

(0.9)

-

-

(0.9)

Netting DTA/DTL

-

-

-

-

-

-

(21.2)

(21.2)

At 31 December 2023

310.8

0.5

0.4

0.1

6.6

-

(80.2)

238.2

At 1 January 2024

310.8

0.5

0.4

0.1

6.6

-

(80.2)

238.2

Acquired through business combinations

-

-

-

-

-

-

-

-

Additions

11.2

-

-

-

-

-

-

11.2

Charge / credited to the income statement

(10.0)

0.1

0.4

2.1

-

-

-

(7.4)

Exchange differences

(0.4)

-

-

(0.4)

(0.1)

-

-

(0.9)

Netting DTA/DTL

-

-

-

-

-

-

(0.3)

(0.3)

At 31 December 2024

311.6

0.6

0.8

1.8

6.5

-

(80.5)

240.8

Additions relate to deferred tax liability recognised for purchase price allocation for acquired entities during 2024. The category Other includes outside base difference of €3.2 million and €0.2 million deferred tax liabilities recognised for contracts that are, or contain, a lease as per requirements set out in IFRS 16 Leases.

An overview of the non-capitalised losses and carry forward interest expenses is shown below:

In millions of Euro

Carry-forward losses

Carry-forward interest

Total

Netherlands

43.2

295.4

338.6

Brazil

34.1

-

34.1

Curaçao

19.9

-

19.9

Switzerland

4.8

-

4.8

Singapore

3.6

-

3.6

Other

2.7

-

2.7

Total at 31 December 2024

108.3

295.4

403.7

The tax losses and non-deductible interest expenses available in the Netherlands can be carried forward indefinitely, but the utilisation of losses is limited to 50% of the taxable income. The losses in Brazil can be carried forward indefinitely but are limited to 30% of the taxable income. The losses in Curaçao can be carried forward for 10 years. The losses in Switzerland can be carried forward for 7 years. The losses in Singapore can be carried forward indefinitely and are subject to a shareholding test.