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Friday, February 19, 2016<br />

6.4 Deferred tax assets and liabilities<br />

Changes in deferred tax assets/(liabilities), net<br />

Year ended December 31,<br />

(in millions of euros) 2015 2014<br />

Opening balance of deferred tax assets/(liabilities), net 53 53<br />

Provision for income taxes (49) (53) (a)<br />

Charges and income directly recorded in equity (67) 54<br />

Business combinations - 9<br />

Divestitures in progress or completed - (20)<br />

Changes in foreign currency translation adjustments and other (20) 10<br />

Closing balance of deferred tax assets/(liabilities), net (83) 53<br />

a. Included in 2014 income/(charges) related to taxes from discontinued operations: in accordance with IFRS 5, these amounts were<br />

reclassified to the line “Earnings from discontinued operations” in the Consolidated Statement of Earnings.<br />

Components of deferred tax assets and liabilities<br />

(in millions of euros) December 31, 2015 December 31, 2014<br />

Deferred tax assets<br />

Recognizable deferred taxes<br />

Tax attributes - Vivendi SA - French Tax Group System (a) (b) 809 1,400<br />

Tax attributes - US Tax Group (a) (c) 445 419<br />

Tax attributes - Other (a) 573 656<br />

Other 609 542<br />

Of which non-deductible provisions 107 117<br />

employee benefits 193 185<br />

net working capital 136 105<br />

Total gross deferred taxes 2,436 3,017<br />

Deferred taxes, unrecognized<br />

Tax attributes - Vivendi SA - French Tax Group System (a) (b) (725) (1,274)<br />

Tax attributes - US Tax Group (a) (c) (445) (419)<br />

Tax attributes - Other (a) (476) (462)<br />

Other (168) (152)<br />

Total deferred tax assets, unrecognized (1,814) (2,307)<br />

Recorded deferred tax assets 622 710<br />

Deferred tax liabilities<br />

Asset revaluations (d) (422) (484)<br />

Other (283) (173)<br />

Recorded deferred tax liabilities (705) (657)<br />

Deferred tax assets/(liabilities), net (83) 53<br />

a. The amounts of tax attributes, as reported in this table, were estimated at the end of the relevant fiscal years. In jurisdictions which are<br />

significant to Vivendi, mainly France and the United States, tax returns are filed on May 1 st and September 15 th of the following year at<br />

the latest, respectively. The amounts of tax attributes reported in this table and the amounts reported to the tax authorities may<br />

therefore differ, and if necessary, may need to be adjusted at the end of the following year in the table.<br />

b. Related to deferred tax assets recognizable in respect of tax attributes by Vivendi SA as head of the French Tax Group, representing<br />

€809 million as of December 31, 2015 (please refer to Note 6.1), related only to tax losses, taking into account the estimated impact<br />

(-€507 million) of 2015 transactions (taxable income and use or expiration of tax credits) and the change in income tax rate in France<br />

which decreased from 38% to 34.43% as from January 1, 2016 (-€84 million), but before taking into account the effects of ongoing tax<br />

audits (please refer to Note 6.5). In France, tax losses can be carried forward indefinitely and Vivendi considers that tax credits can be<br />

carried forward for a minimum period of five years upon exit from the Consolidated Global Profit Tax System. In this respect,<br />

€285 million tax credits matured as of December 31, 2015.<br />

c. Related to deferred tax assets recognizable in respect of tax attributes by Universal Music Group, Inc. in the United States as head of<br />

the US Tax Group, representing $486 million as of December 31, 2015, taking into account the estimated impact (-$23 million) of 2015<br />

transactions (taxable income, capital losses, and tax credits that expired, capital losses and tax credits generated, but before taking into<br />

account the final outcome of ongoing tax audits (please refer to Note 6.5). In the United States, tax losses can be carried forward for a<br />

Financial Report and Audited Consolidated Financial Statements for the year ended December 31, 2015 Vivendi /62

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