12. Income tax (expense)/benefit

The current income tax expense is calculated on the basis of the tax laws enacted or substantively enacted at the balance sheet date in the countries where TMF Group operates and generates taxable income.

Management periodically evaluates positions taken in tax returns with respect to situations in which applicable tax regulations are subject to interpretation and establishes provisions, where appropriate, on the basis of amounts expected to be paid to the tax authorities.

Income tax expense comprises current and deferred tax. Income tax expense is recognised in the income statement, except where it relates to items recognised directly in equity, in which case it is recognised in equity. Where income tax expense relates to items recognised in other comprehensive income (OCI), it is recognised in OCI.

Current tax is the expected tax payable on the taxable income for the year, using tax rates enacted, or substantively enacted, at the reporting date, and any adjustments to tax payable in respect of previous years.

The tax on TMF Group's result before tax differs from the theoretical calculation that would arise using the UK tax rate (25.0%) applied to the results of the consolidated entities, as shown below:

* The non-deductible expenses mainly relate to financing costs.

TMF Group is a Jersey company with subsidiaries spread over the world and subject to income tax in the United Kingdom and in the countries where TMF Group conducts operations. Based on the assessment of governance structure, decision‑making processes, and place of effective management, TMF Group was determined to be tax resident in the United Kingdom. As part of its normal course of business, TMF Group has uncertain tax positions and exposures resulting from the interpretation of applicable tax laws applied in our tax returns. If any uncertain tax positions have been assessed, they are provided for under current income tax liabilities, as required under the newly adopted accounting guidance in IFRIC. The adoption did not impact the financial position. TMF Group's transfer pricing model is consistent with the arm’s length principle and in accordance with the OECD transfer pricing guidelines.

TMF Group has its Ultimate Parent Entity in the United Kingdom, where the Global Minimum Tax Rules are enacted for fiscal years starting on or after 1 January 2024. TMF Group operates in 88 countries, including a number of countries that, during the year ended 31 December 2025, did not have a corporate income tax system or had a corporate income tax system with a statutory tax rate lower than 15%. 

TMF Group has applied the mandatory temporary relief from deferred tax accounting for the impacts of the Global Minimum Tax and accounts for it as a current tax when it is incurred.

TMF Group analysed the impact of the Global Minimum Tax Rules and estimates that the profits relating to the Group’s operations in the following countries are subject to Global Minimum Tax: British Virgin Islands (ETR 0%; top-up tax 225 thousand), Bulgaria (ETR 8.63%; top-up tax 92 thousand), Cayman Islands (ETR 6.30%; top-up tax 88 thousand), United Arab Emirates (ETR 9.03%; top-up tax 228 thousand).