20 Deferred tax

Tax accruals and deferrals recognised in the balance sheet on temporary differences between the amounts stated in the IFRS financial statements and the respective tax amounts as well as on losses carried forward developed as follows:

Deferred tax on losses carried forward was capitalised as these can probably be offset with future taxable profits. The planning period is limited to five years.

No deferred tax on losses carried forward of the STRABAG SE Group was recognized as the unused portions of investment impairment must be used primarily. The Austrian Corporate Income Tax (Körperschaftsteuergesetz, KStG) stipulates that impairment on investments can only be deducted for tax purposes over seven years (“ Siebentelabschreibung”).

The tax planning for the STRABAG SE tax group for the next five years documents the usability of the “Siebentelabschreibung”.

As at 31 December 2024, there were differences of T€ 1,099,276 (2023: T€ 1,086,560) between the carrying amount and the equity of subsidiaries recognised in the Group. No deferred taxes were recognised as STRABAG determines the disposal and dividend policy of the subsidiaries. STRABAG can therefore control the timing of the reversal of the temporary differences. The Management Board assumes that there will be no reversals in the foreseeable future.

Based on the rules developed by the OECD for the introduction of a global minimum tax, the EU on 22 December 2022 adopted a directive on a global minimum level of taxation. In Austria, implementation into national law was carried out with the Minimum Tax Act, which became applicable for the first time for the 2024 financial year. The new law requires STRABAG SE to pay additional taxes for its subsidiaries in jurisdictions in which the effective tax rate determined in accordance with Pillar II is below 15%, insofar as an additional tax is not levied in the respective jurisdiction itself.

With Hungary, Bulgaria, Montenegro, Bosnia and the United Arab Emirates, the STRABAG SE Group operates in countries with a nominal tax rate below 15%. With the exception of Montenegro and Bosnia, these countries have introduced a national top-up tax, which has resulted in only minor top-up tax amounts that have been recognised in the local financial statements. The majority of the operating business, however, is conducted in countries with higher tax rates (in particular Germany and Austria). Based on a preliminary analysis of the tax expenses and earnings of the Group companies, no provision for tax expenses under the Pillar II rules had to be recognised in the consolidated financial statements for the 2024 financial year.

In accordance with the provisions of IAS 12, the exemption from recognising deferred taxes due to Pillar II is applied.

With regard to deferred taxes, these can only be taken into account for Pillar II purposes provided that the deferred tax assets and liabilities in the financial accounts of all business entities in a tax jurisdiction for the transition year have been demonstrably recognised or disclosed in financial statements.

The following table therefore shows all unrecognised deferred taxes on losses carried forward and temporary differences. In the absence of a reversal of deferred taxes in the next five years, an impairment was made with regard to these losses carried forward and temporary differences in the consolidated financial statements. Determination of the impairment took into account the fact that losses carried forward exist in project companies with only limited business activities in subsequent years and that losses carried forward are recognised multiple times in the investment chain due to tax-effective investment write-downs and that their use would lead to tax-effective write-ups.

Of the non-capitalised losses carried forward, T€ 2,919,592 (2023: T€ 2,632,108) have unrestricted use. Non-capitalised losses carried forward in the amount of T€ 189,843 (2023: T€ 260,625) can theoretically be used for up to 20 years (2023: 20 years).

The unrecognised deferred taxes are as follows: