ORANO // Annual Activity Report 2024
6
STATEMENTS Consolidated fi nancial statements - fi nancial year ended December 31, 2024
NOTE 8 INCOME TAX
ANALYSIS OF INCOME TAX EXPENSE
December 31, 2024 December 31, 2023
(in millions of euros)
Current taxes (France)
(31) (78)
(22) (80)
Current taxes (other countries)
Total current taxes
(109)
(102)
Deferred taxes TOTAL TAXES
55
(7)
(54)
(109)
The main French subsidiaries in the scope of consolidation, which are at least 95% owned, established an Orano SA tax consolidation group effective September 1, 2017. Future relationships between the subsidiaries and Orano SA for the period covered by the tax consolidation are governed by a tax consolidation agreement, based on the principle of neutrality. At December 31, 2024, the group’s pro fi t outlook allows for the recognition of a deferred tax asset, mainly in respect of tax loss carryforwards and certain temporary differences. Deferred taxes recognized in the income statement include the impact of this recognition as well as that of uncertain tax positions classi fi ed in the statement of fi nancial position as deferred tax liabilities. Uncertain tax positions relating to current tax are classi fi ed in the statement of fi nancial position as current tax liabilities.
The international tax reform approved by the OECD at the end of 2021, known as “Pillar 2”, aimed in particular at establishing a minimum tax rate of 15%, was adopted in France before December 31, 2023 as part of the Finance law for 2024. It came into effect from the fi nancial year beginning January 1, 2024. Due to its revenue, Orano falls within the scope of application of this reform from January 1, 2024. In this context, Orano SA is the Ultimate Parent Entity (“UPE”) and could be liable, where applicable, for additional tax in respect of its low-tax subsidiaries. For the 2024 fi nancial year, the Orano group should not be liable for any additional tax.
RECONCILIATION BETWEEN INCOME TAX EXPENSE AND PROFIT(LOSS) BEFORE TAX
December 31, 2024 December 31, 2023
(in millions of euros)
Net income for the period
712
322
Share in net income of joint ventures and associates
12 54
3
Tax expense (income) Income before tax
109 434
778
Theoretical tax (expense) / gain at 25.83%
(201)
(112)
Impact of tax consolidation OPERATIONS TAXED AT A RATE OTHER THAN THE FULL STATUTORY RATE
-
-
Unrecognized / recognized deferred taxes Other changes in permanent differences
157 (10) (54)
40
(38)
Actual tax (expense) / income
(109)
EFFECTIVE TAX RATE
7%
25%
BREAKDOWN OF OTHER CHANGES IN PERMANENT DIFFERENCES
December 31, 2024 December 31, 2023
(in millions of euros)
Parent/subsidiary tax treatment and inter-company dividends Differences between the French tax rate and tax rates applicable abroad
(2) 27 (6) (3)
(1) (3) (7)
CVAE business tax
Impact of change in tax rate
3
Other
(27) (10)
(29) (38)
TOTAL OTHER CHANGES IN PERMANENT DIFFERENCES
344
Orano - Annual Activity Report 2024
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