25 – Deferred taxes

Deferred taxes were mainly related to different valuation methods, differences in impairments, write-offs, write-ups and depreciation and amortization as well as different definition of costs.

Decrease in deferred tax liabilities (DTL) related to intangible assets was mainly driven by deconsolidation of JSC GAZPROM YRGM Development. For further details see Note 2 – Accounting policies, judgements and estimates, section ‘Impact of Russia’s invasion of Ukraine and related significant estimates and assumptions’.

Increase in deferred tax assets (DTA) related to tax impairments was mainly drived by the impairment of investment in JSC GAZPROM YRGM Development. For further details see Note 12 – Taxes on income and profit.

The overall net DTA position of tax jurisdictions which suffered a tax loss either in current or preceding year amounted to EUR 682 mn, thereof EUR 522 mn is attributable to the Austrian tax group (2021: EUR 901 mn, thereof Austrian tax group EUR 658 mn).

In 2022 as well as in the previous year, a valuation allowance for DTA for the Austrian tax group was recognized. DTA recognized for the AT Tax Group as of December 31, 2022 reflects the expected utilization of deductible temporary differences of balance sheet items and tax losses carried forward based on the mid term plan for the period 2023 – 2027. Limitation to the usage of tax losses of 75%, as stipulated by the Austrian Corporate Income Tax Act, was considered in the assessment of the recoverable DTA within the planning period. Remaining DTL after the planning period are mainly expected to be offset with DTA from temporary differences. Any remaining DTL after netting is assumed to be offset with DTA from tax losses, therefore the limitation to the usage of tax losses have not been considered after the planning period. This is also supported by the fact that tax losses can be carried forward for an unlimited period of time.

As of December 31, 2022, OMV recognized tax losses carryforward of EUR 6,758 mn before allowances (2021: EUR 5,839 mn), thereof EUR 3,460 mn (2021: EUR 3,202 mn) are considered recoverable for calculation of deferred taxes.

Eligibility of losses for carryforward expires as follows:

The majority of tax losses carryforward not recognized referred to the Austrian Tax Group and France.

As of December 31, 2022, the aggregate amount of temporary differences associated with fully consolidated and equity-accounted investments for which deferred tax liabilities have not been recognized amounted to EUR 10,123 mn (2021: EUR 7,475 mn). Capital gains on disposals of investments may be realized on various levels of the Group depending on the structuring of potential divestments. Due to the complexity of the group and the associated tax implications simplifying assumptions for the calculation have been made that aim to diminish cascade effects.