ÖBB Annual Report 2023
261 Consolidated Financial Statements Österreichische Bundesbahnen-Holding Aktiengesellschaft Consolidated Financial Statements | Group Management Report 43 Tax loss carryforwards of approx. EUR 4,588.8 million (py: approx. EUR 4,884.1 million) originate from Austrian companies and are eligible to be carried forward indefinitely under current legislation. The annual offsetting against loss carryforwards in Austria is limited to 75% of the respective tax result, but approx. EUR 2,574.2 million (py: approx. EUR 2,911.4 million) results from the pre-Group losses and eligible therefore to offset in full against tax results achieved in future periods. Loss carryforwards from foreign companies amount to approx. EUR 153.4 million (py: approx. EUR 64.0 million ). The Hungarian company Rail Cargo Hungaria Zrt reports a loss carryforward of approx. EUR 148.4 million that is not subject to time limitation and for which no deferred tax assets are recognised. Similarly, the Czech company Rail Cargo Operator – ČSKD s.r.o. recognised no deferred tax assets on its loss carryforward in the amount of approx. EUR 0.3 million. The Italian company Rail Cargo Logistics – Terminals Italy s.r.l. reported a loss carryforward of approx. EUR 0.7 million, on which no deferred tax assets were recognised. The Italian subsidiary Rail Cargo Carrier – Italy s.r.l. was able to recognise deferred tax assets on its loss carryforwards of approx. EUR 1.4 million, while the company ooo Rail Cargo Logistics – RUS was also able to recognise deferred tax assets on its loss carryforwards of approx. EUR 1.0 million, which are expected to be utilised next year. The Czech company Rail Cargo Terminal – Praha s.r.o. recognises deferred tax assets on its loss carryforwards amounting to approx. EUR 1.5 million. The company assumes that will be able to realise its losses in full in the coming year. As of 31.12.2023, there were outstanding sevenths of depreciation on participations not yet claimed as operating expenses pursuant to Section 12 (3) Corporate Income Tax Act amounting to approx. EUR 38.5 million (py: approx. EUR 49.4 million). No deferred tax assets were recognised in this regard. No deferred taxes were recognised in respect of temporary differences from investments in associates and subsidiaries amounting to approx. EUR 940.6 million (py: approx. EUR 1,311.4 million).
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