Annual Report 2025 – ÖBB-Infrastruktur AG
ÖBB-Infrastruktur Aktiengesellschaft Consolidated Management Report | Consolidated Financial Statements 180 Research and development costs Research expenses relate to the independent and planned search for new scientific or technical findings in accordance with IAS38 “Intangible Assets” and are recognised as expenses in the period in which they are incurred. Development expenses are costs incurred when research findings are applied to make them technically and economically feasible. If research and development expenses cannot be separated, development expenses are to be recorded as expenses in the period in which they are incurred, in accordance with AS38. If the recognition requirements of IAS 38 are met, development expenses are to be capitalised as intangible assets. Tax position Pursuant to Section 50 (2) Federal Railways Act as amended by Federal Law Gazette No. 95/2009, ÖBB-Infrastruktur AG has been exempt from federal taxes with the exception of value-added tax, from federal administrative levies and from court and judicial administrative levies since 2005, insofar as these levies and charges result from the performance of the respective tasks provided for in the Federal Railways Act (partial tax exemption) by ÖBB-Infrastruktur AG. Essentially, the following areas have been classified as subject to income tax: – Income from the electric power business – Rendering non-railway infrastructure-related services – Management (including development and sale) of real estate that does not constitute railway assets within the meaning of Section10a Railways Act (Eisenbahngesetz) – Investment management In December 2005, a contract on group taxation was concluded with ÖBB-HoldingAG as head of the tax group and the majority of the ÖBB Group companies as group members, including ÖBB-Infrastruktur AG and its subsidiary companies as group members. Accordingly, tax equalisation arrangements were agreed between the Group parent and the Group members. The positive tax contributions determined according to these provisions are calculated using the stand-alone method (assuming tax independence of the individual group members for the calculation of the contribution). Negative tax allocations are only compensated to the affected group members when the losses are effectively utilised by the group entity. The tax allocations will become due after the tax field audit has been completed and the group parent's corporate income tax assessment has become final. A turnover group has been formed with ÖBB-HoldingAG as the controlling company in accordance with Section 2 (2) of the Turnover Tax Act (UStG). Income taxes and deferred taxes Income taxes include both current and deferred taxes. Current taxes include all taxes levied on the taxable income of the group companies. Other taxes, such as property or operating taxes (electricity, energy), are included in the corresponding operating expenses. Deferred tax assets and liabilities are recognised in accordance with IAS 12 Income Taxes for all temporary differences between tax and IFRS balance sheet values, for tax credits and loss carry forwards in the consolidated financial statements. Deferred taxes are recognised – subject to existing exemption provisions – for all temporary differences between the tax base of assets and debts (“Tax base”) and their carrying amounts in the IFRS financial statements (so-called liability method), insofar as these relate to assets and debts connected with non-exempt business operations. If a transaction that does not qualify as a business combination, deferred taxes arise from the initial recognition of an asset or liability that, at the time of the transaction, has no effect on either the accounting profit or loss or the taxable income, no deferred taxes are recognised either at the time of initial recognition or thereafter. Deferred tax liabilities arising from temporary differences in conjunction with investments in subsidiaries and associated companies are recognised, unless the ÖBB-Infrastruktur 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 claims are realised or the deferred tax debts are expected to be settled. Deferred tax assets are recognised to the extent that it is probable that future taxable profit will be available against which the temporary differences and loss carryforwards are utilised. The International Tax Reform – Pillar II legislation (global minimum taxation) – already passed into Austrian law as of 31.12.2023. The law applies for financial years beginning after 31.12.2023. The ÖBB-Infrastruktur Group continually evaluates whether it is fundamentally affected and identifies the jurisdictions from which the Group is exposed to potential
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