ÖBB Annual Report 2025

223 Consolidated Financial Statements Österreichische Bundesbahnen-Holding Aktiengesellschaft Consolidated Financial Statements | Group Management Report 31 When utilizing tax losses, the primacy of the sub-group consideration and the principle of equal treatment of all participants in the corporate group within the respective sub-group apply; in addition, the principle of equal treatment for all partici- pants in the corporate group applies for inter-sub-group utilization of financial losses. As of the reporting date, the tax group of the VAT group in accordance with Section2 Austrian VAT Act ( Umsatzsteuerge- setz – UStG) consists of the controlling company ÖBB-HoldingAG and several Austrian companies of the ÖBB Group. Income taxes and deferred taxes Income taxes include both current and deferred taxes. Current taxes relate to all taxes levied on the taxable profit of Group companies. Other taxes such as asset-related taxes or operating taxes (power, energy) are included in the corresponding operating expenses. Deferred tax assets and liabilities are recognized in accordance with IAS 12 “Income Taxes” for all temporary differences between tax and IFRS carrying amounts, for tax credits, and loss carry forwards in the Consolidated Financial Statements. Deferred taxes are recognized – taking existing exception clauses into account – for all temporary differences between the tax base of the assets and liabilities and their carrying amounts in the IFRS financial statements (liability method), insofar as these assets and liabilities are related to the business operation that is not exempt from income taxes. Deferred tax assets and deferred tax liabilities in connection with the global minimum taxation are not recognized due to the existing temporary exception of IAS12. If deferred taxes arise from the initial recognition of an asset or a liability resulting from a transaction other than a business combination which neither affects the accounting profit or loss nor the taxable profit at the time of the transaction, no deferred taxes are recognized at the time of initial recognition and thereafter. Deferred tax liabilities arising from temporary differences in connection with investments in subsidiaries and associated companies are recognized, unless the ÖBB Group is able to control the timing of the reversal of the temporary differences and it is probable that the temporary differences will not reverse in the foreseeable future due to this influence. Deferred taxes are measured at the tax rates (and under the tax regulations) that have been enacted or substantially enacted on the reporting date and that are expected to apply in the period when the deferred tax assets are realized or the deferred tax liabilities are expected to be settled. Deferred tax assets are recognized to the extent that it is probable that future taxable profit against which the temporary differences or loss carry-forwards can be utilized will be available. As of December 31, 2023, the international tax reform – Pillar II legislation (global minimum taxation) – has already been transposed into Austrian law. The law applies for the first time to financial years beginning after December 31, 2023. The ÖBB Group falls within the scope of these regulations. The ÖBB Group continuously evaluates the fundamental impact and determines the jurisdictions from which the Group is exposed to possible impacts in connection with a Pillar II top-up tax (primary supplementary tax) or a Qualified Domestic Minimum Top-up Tax (national supplementary tax). The top-up tax is applied at the level of ÖBB-Holding AG. At local level, ÖBB-Holding AG Group companies may be subject to any national supplementary taxes. The Group closely monitors the progress of the local legislative process in each country in which the ÖBB Group operates. The ÖBB Group continuously reviews the impacts of the Pillar II legislation on the future profitability of the Group. The analysis did not result in any amounts of minimum tax (top-up tax) to be paid on the profits of subsidiaries domiciled in countries where the statutory tax rate is below the minimum tax rate of 15%. The relief provision of IAS 12, according to which no deferred taxes resulting from the introduction of global minimum taxation are recognized, is applied.