Accounting Policy
In addition to corporate income taxes and trade earnings taxes, typical E&P taxes from oil and gas production, like the country/national oil company’s profit share for certain EPSAs, are disclosed as income taxes.
Exploration and production sharing agreements (EPSAs) are contracts for oil and gas licenses in which the oil or gas production is shared between one or more oil companies and the host country/national oil company in defined proportions. Exploration expenditures are carried by the oil companies as a rule and recovered from the state or the national oil company through what is known as “cost oil” in a successful case only. Under certain EPSA contracts, the host country’s/national oil company’s profit share represents imposed income taxes and is treated as such for the purpose of the income statement presentation.
Deferred taxes are recognized for temporary differences. Deferred tax assets (DTA) are recognized to the extent that it is probable that taxable profit will be available, against which the unused tax losses, unused tax credits, and deductible temporary differences can be utilized.
The Group has applied the mandatory temporary exception to the recognition and disclosure of information about DTA and deferred tax liabilities (DTL) arising from Pillar Two income taxes.
Significant Estimates: Recoverability of DTA
The recognition of DTA requires an assessment of when those assets are likely to reverse, and an evaluation as to whether or not there will be sufficient taxable profits available to offset the assets when they reverse. This assessment of recoverability requires assumptions regarding future taxable profits and is therefore uncertain. At OMV, this assessment is based on detailed tax planning that covers the life span of fields in E&P entities and a five-year period in the other entities.
In both 2025 and the previous year, a valuation allowance for the DTA of the Austrian tax group was recognized. The DTA recognized for the Austrian tax group as of December 31, 2025, reflects the expected utilization of deductible temporary differences of balance sheet items and tax losses carried forward during the 5-year planning horizon. A 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 and after the planning period.
Changes in the assumptions regarding future taxable profits can lead to an increase or decrease in the amount of DTA recognized, which has an impact on the net income in the period in which the change occurs.
In EUR mn |
|
|
|
2025 |
2024 |
|---|---|---|
Profit before tax |
3,047 |
4,099 |
Current taxes |
1,825 |
2,147 |
thereof related to previous years |
42 |
–16 |
Deferred taxes |
9 |
16 |
Taxes on income and profit |
1,834 |
2,163 |
In EUR mn |
|
|
|
2025 |
2024 |
|---|---|---|
Deferred taxes |
4 |
3 |
Current taxes |
– |
– |
Taxes on income and profit accounted for in other comprehensive income – continuing operations |
4 |
3 |
Taxes on income and profit accounted for in other comprehensive income – discontinued operations |
15 |
–5 |
Total taxes on income and profit accounted for in other comprehensive income |
18 |
–2 |
In EUR mn |
|
|
||||
|
2025 |
2024 |
||||
|---|---|---|---|---|---|---|
Deferred taxes as of January 1 |
182 |
–114 |
||||
Deferred taxes as of December 31 |
108 |
182 |
||||
Changes in deferred taxes |
–74 |
297 |
||||
Deferred tax |
–56 |
1 |
||||
Deferred taxes accounted for in OCI or directly in equity |
–17 |
3 |
||||
Changes in the consolidated group, currency translation differences, and other changes2 |
8 |
309 |
||||
Deferred tax expenses per income statement |
–9 |
–16 |
||||
The deferred taxes per income statement comprise the following elements: |
|
|
||||
Change in tax rate |
15 |
1 |
||||
Non-recognition and changes in valuation allowance of DTA |
–147 |
14 |
||||
Adjustments within loss carryforwards (not recognized in prior years, expired loss |
–12 |
–10 |
||||
Additions to and usage of loss carryforwards |
146 |
–64 |
||||
Origination and reversal of temporary differences |
–11 |
44 |
||||
|
||||||
OMV Aktiengesellschaft forms a tax group in accordance with Section 9 of the Austrian Corporate Income Tax Act 1988 (KStG), which aggregates the taxable profits and losses of all the Group’s main subsidiaries in Austria and possibly arising losses of one foreign subsidiary (OMV AUSTRALIA PTY LTD).
Dividend income from domestic subsidiaries is in general exempt from taxation in Austria. Dividends from EU and EEA participations as well as from subsidiaries whose country of residence has a comprehensive mutual administrative assistance agreement with Austria are exempt from taxation in Austria if certain conditions are met. Dividends from other foreign investments that are comparable to Austrian corporations, for which the Group holds a 10% investment share or more for a minimum period of one year, are also excluded from taxation at the level of the Austrian parent company.
The change in the valuation allowance of deferred taxes for the Austrian tax group was reported in the income statement, except to the extent that the DTA arose from transactions or events that were recognized outside profit or loss, i.e., in other comprehensive income or directly in equity.
As disclosed in Note 4 – OMV and ADNOC to Establish a New Polyolefins Joint Venture, Borouge Group International AG and some entities of Borealis Group are members of the Austrian Tax Group and will continue to be part of the Austrian Tax Group after the closing of the transaction via joint tax grouping (“Beteiligungsgemeinschaft”). A proportional share of the taxable result of the joint tax group will be allocated to the Austrian Tax Group. Consequently, the recoverable DTA of the Austrian Tax Group was reassessed in March 2025.
Global Minimum Tax
In December 2023, the Pillar Two legislation (Mindestbesteuerungsgesetz) effective from January 1, 2024, was enacted in Austria, where the ultimate parent company of the Group is incorporated. Under this legislation, Group companies are subject to Pillar Two income taxes on profits that are taxed at an effective tax rate of less than 15%. Certain subsidiaries of the Group are subject to a qualified domestic minimum tax in the countries where Pillar Two rules were transposed into national law.
The Group has performed a preliminary calculation of transitional safe harbors for Pillar Two purposes. Based on the preliminary safe harbor calculation and the detailed Pillar Two calculation for those jurisdictions not qualifying for the safe harbors, no material exposure to Pillar Two income taxes is expected for financial year 2025.
Effective Tax Rate
The effective tax rate is the ratio of income tax to profit before tax. The table below reconciles the effective tax rate and the standard Austrian corporate income tax rate of 23% (2024: 23%), showing the major influencing factors.
|
2025 |
2024 |
||
|---|---|---|---|---|
|
In EUR mn |
In % |
In EUR mn |
In % |
Theoretical taxes on income based on Austrian income tax rate |
701 |
23.0 |
943 |
23.0 |
Tax effect of: |
|
|
|
|
Differing foreign tax rates |
939 |
30.8 |
1,149 |
28.0 |
Non-deductible expenses |
224 |
7.4 |
267 |
6.5 |
Non-taxable income and tax incentives |
–53 |
–1.7 |
–45 |
–1.1 |
Income and expenses related to equity-accounted investments |
–97 |
–3.2 |
–137 |
–3.3 |
Change in tax rate |
–15 |
–0.5 |
–1 |
–0.0 |
Permanent effects within tax loss carryforwards |
–0 |
–0.0 |
14 |
0.4 |
Tax |
–27 |
–0.9 |
–32 |
–0.8 |
Non-recognition and changes in valuation allowance of DTA |
147 |
4.8 |
–14 |
–0.3 |
Taxes related to previous years |
29 |
1.0 |
1 |
0.0 |
Other |
–13 |
–0.4 |
18 |
0.4 |
Total taxes on income and profit |
1,834 |
60.2 |
2,163 |
52.8 |
Differing foreign tax rates effects in 2025 related mostly to subsidiaries operating in tax jurisdictions with high corporate income tax rates (Norway, United Arab Emirates, and Libya). The decrease in the effects related to differing foreign tax rates compared to 2024 was mostly due to the lower profit before tax of those subsidiaries.
Non-deductible expenses related mostly to the gross-up effects related to exploration and production sharing agreements, permanent effects related to depreciation and amortization, and reassessment of receivables. 2024 was predominantly impacted by the impairment of an oil and gas asset in the Energy segment for which the divestment process was initiated during the year.
Non-taxable income and tax incentives in 2025 mainly related to investment allowances and non-taxable income from penalties and late payment interest, while in 2024 these effects related mostly to government grants and investment allowances.
Income and expenses related to equity-accounted investments effects in 2025 and 2024 were mainly related to the share of profit from equity-accounted investments.
Non-recognition and changes in valuation allowance of DTA in 2025 was mainly impacted by the reassessment of the deferred tax asset position of the Austrian tax group.
Taxes related to previous years in 2025 were mainly attributable to the changes in uncertain tax risk positions, adjustments of prior year impairments, and the effects related to differences between the functional currency and tax currency of certain subsidiaries.
Deferred Taxes
In EUR mn |
|
|
|
|
|
Deferred tax |
Deferred tax assets not recognized |
Deferred tax assets recognized |
Deferred tax liabilities |
|---|---|---|---|---|
|
|
|
|
|
|
2025 |
|||
Intangible assets |
78 |
– |
78 |
52 |
Property, plant, and equipment |
109 |
3 |
106 |
1,643 |
Inventories |
27 |
– |
27 |
20 |
Derivatives |
24 |
– |
24 |
41 |
Receivables and other assets |
88 |
20 |
68 |
70 |
Deferred taxes reclassified to assets and liabilities associated with assets held for sale |
508 |
368 |
140 |
482 |
Provisions for pensions and similar obligations |
122 |
81 |
41 |
84 |
Provisions for decommissioning, restoration obligations, and environmental costs |
1,293 |
15 |
1,278 |
– |
Other provisions |
81 |
– |
81 |
3 |
Liabilities |
182 |
37 |
145 |
19 |
Tax impairments according to |
337 |
– |
337 |
– |
Tax loss carryforwards |
1,178 |
982 |
196 |
– |
Total |
4,028 |
1,506 |
2,522 |
2,413 |
Netting (same tax jurisdictions) |
|
|
–1,307 |
–1,307 |
Deferred taxes reclassified to assets and liabilities associated with assets held for sale |
|
|
–10 |
–352 |
Deferred taxes as per statement of financial position |
|
|
1,205 |
754 |
|
|
|
|
|
|
2024 |
|||
Intangible assets |
112 |
– |
112 |
214 |
Property, plant, and equipment |
142 |
5 |
137 |
2,255 |
Inventories |
47 |
– |
47 |
33 |
Derivatives |
22 |
– |
22 |
49 |
Receivables and other assets |
113 |
22 |
92 |
253 |
Provisions for pensions and similar obligations |
209 |
97 |
112 |
109 |
Provisions for decommissioning, restoration obligations, and environmental costs |
1,208 |
25 |
1,183 |
– |
Other provisions |
103 |
– |
103 |
1 |
Liabilities |
345 |
36 |
308 |
0 |
Tax impairments according to |
476 |
– |
476 |
– |
Tax loss carryforwards |
1,438 |
1,075 |
364 |
– |
Outside basis differences |
141 |
– |
141 |
– |
Total |
4,357 |
1,259 |
3,097 |
2,915 |
Netting (same tax jurisdictions) |
|
|
–1,845 |
–1,845 |
Deferred taxes as per statement of financial position |
|
|
1,252 |
1,070 |
Deferred taxes were mainly related to different valuation methods, differences in impairments, write-offs, write-ups, and depreciation and amortization, as well as different definitions of costs.
Deferred taxes reclassified to assets and liabilities associated with assets held for sale pertained entirely to discontinued operations. For further details, see Note 4 – OMV and ADNOC to Establish a New Polyolefins Joint Venture.
As of December 31, 2025, deductible temporary differences for which no DTA was recognized amounted to EUR 629 mn (2024: EUR 729 mn).
The overall net DTA position of tax jurisdictions that suffered a tax loss either in the current or preceding year amounted to EUR 612 mn (2024: EUR 10 mn), of which EUR 320 mn is attributable to the Austrian tax group (2024: nil).
Tax Loss Carryforwards
As of December 31, 2025, OMV recognized tax loss carryforwards of EUR 4,979 mn before allowances (2024: EUR 6,108 mn), of which EUR 757 mn (2024: EUR 1,539 mn) is considered recoverable for the calculation of deferred taxes.
The eligibility of losses to be carried forward expires as follows:
In EUR mn |
|
|
|
|
||
|
2025 |
2024 |
||||
|---|---|---|---|---|---|---|
|
Base amount (before allowances) |
thereof not recognized |
Base amount (before allowances) |
thereof not recognized |
||
2025 |
– |
– |
11 |
11 |
||
2026 |
3 |
3 |
3 |
3 |
||
2027 |
3 |
3 |
3 |
3 |
||
2028 |
2 |
2 |
2 |
2 |
||
2029 |
1 |
1 |
4 |
3 |
||
2030 |
6 |
3 |
– |
– |
||
After 2030/2029 |
1 |
– |
0 |
– |
||
Unlimited |
4,963 |
4,210 |
6,085 |
4,547 |
||
Tax loss carryforwards |
4,979 |
4,222 |
6,108 |
4,569 |
||
|
||||||
In certain tax jurisdictions, local tax laws stipulate limitations on the usage of tax losses carried forward. These limitations range from 50% up to 80% of the taxable profit for the year. As of December 31, 2025, tax loss carryforwards related to tax jurisdictions with the aforementioned limitations amounted to EUR 4,613 mn (2024: EUR 5,725 mn), of which EUR 676 mn (2024: EUR 1,470 mn) is considered recoverable for the calculation of deferred taxes.
The majority of tax loss carryforwards not recognized referred to the Austrian tax group.
Outside Basis Differences
As of December 31, 2025, the aggregate amount of temporary differences associated with fully consolidated and equity-accounted investments in continuing operations, for which deferred tax liabilities have not been recognized, amounted to EUR 5,052 mn (2024: EUR 9,667 mn).
The exception criteria as per IAS 12 for not recognizing these deferred tax liabilities is deemed to be fulfilled due to the fact that the Group is able to control or influence the relevant decisions with respect to the timing of the reversal and it is not probable that temporary differences will reverse in the foreseeable future or the Group intends to reinvest undistributed profits. 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.