Annual Report 2025 – ÖBB-Infrastruktur AG

ÖBB-Infrastruktur Aktiengesellschaft Consolidated Management Report | Consolidated Financial Statements 191 Based on the taxable income of previous years and the forecasts of taxable income for future years in which tax assets can be utilised, the Management Board is of the opinion that the realisation of tax benefits from deferred tax assets in the sum of approximately EUR 73.8 million (previous year: approximately EUR 70.7 million) is probable. The temporary differences in the property, plant and equipment and investment property items largely result from the different start of depreciation (pro rata temporis under IFRS compared to the half-year rule under tax law) as well as from different tax acquisition costs and from the recognition of items in accordance with IFRS 16. The temporary differences in inventories result from different tax acquisition costs. The temporary differences in financial assets and liabilities result from the different measurement of electricity derivatives under IFRS (measurement at fair value) and tax law (provision for onerous contracts). The financial liabilities largely include the temporary differences from lease liabilities in accordance with IFRS16. Deferred tax liabilities on electricity derivatives are mainly recognised in other comprehensive income. The decline in deferred tax liabilities on electricity derivatives also results in a decline in deferred tax assets on tax loss carryforwards, which is, however, recognised in profit or loss. The tax loss carryforwards originate from Austria and are eligible to be carried forward indefinitely. The annual offsetting against loss carryforwards in Austria is limited to 75% of the respective tax result. However, approximately EUR 1,530.4 million (previous year: approximately EUR 1,575.5 million) result from the pre-Group losses of ÖBB-Infrastruktur AG and are, therefore, eligible to be offset in full against tax results achieved in future periods. The change results from the consideration of differences arising from the assessments made during the financial year and the tax results originally taken into account. No deferred tax assets have been recognised in respect of tax loss carryforwards amounting to approximately EUR 1,275.3 million (previous year: approximately EUR 1,354.9 million), as their utilisation is not considered probable in the foreseeable future. No deferred taxes were recognised on temporary differences in the amount of approximately EUR 9.7 million (previous year: EUR 9.7 million) resulting from investments in associated companies and subsidiaries. The income taxes paid shown in the cash flow statement relate primarily to tax allocations amounting to approximately EUR 6.5 million (previous year: EUR 0.0 million).