Capítulo IV. Resultados y Discusión
IV.6. Desarrollo y optimización de 4 sistemas de Q-PCR para la rápida detección y
IV.6.4. Sistema simultáneo de Q-PCR de trigo/cebada/centeno
Amounts in millions of EUR 2011 2010
Finance income 32 19
Interest on borrowings −662 −827
Interest on provisions −9 −11
Other −19 −22
Finance costs −690 −860
Amortizable part of hedge reserve [19] −6 −11
Ineffective portion of cash flow hedges – –
Ineffective portion of fair value hedges −36 −17
Exchange rate differences −4 2
Other −50 −49
Other financial results −96 −75
Total −754 −916
[..] Bracketed numbers refer to the related notes.
In 2011, interest on borrowings included a non-cash amount of EUR 26 million (2010: EUR 30 million) relating to previously capitalized debt issue costs and similar costs which are amortized over the duration of the respective bonds. Interest on borrowings in 2010 included EUR 97 million of costs regarding the tender on outstanding Eurobonds. These costs included a tender premium of EUR 90 million and EUR 7 million of additional amortization.
97
Consolidated Financial Statements
KPN | Annual Report 2011 Notes to the Consolidated Statement of Income
With regards to the Reggefiber call/put arrangements to acquire 100% of the shares over time, KPN has recorded EUR 55 million in other financial results (2010: EUR 46 million). Refer to Note 12 and Note 29 for further information on the call/put arrangements.
In 2011, a loss of EUR 14 million was recognized in the Consolidated Statement of Income (other other financial results) related to available for sale financial assets (2010: nil).
[7] Taxation
For Dutch tax purposes, KPN Mobile and Koninklijke KPN are separate fiscal unities. The German activities (E-Plus) of KPN form a German partnership transparent for German tax purposes and a permanent establishment for Dutch tax purposes held by KPN Mobile.
KPN Mobile fiscal unity
An agreement in 2004 with the Dutch tax authorities allowed KPN Mobile to offset a EUR 11.5 billion tax loss related to E-Plus against its 2002 Dutch taxable result. This loss had to be recaptured in later years by adding EBITDA of E-Plus to the taxable income of KPN Mobile. For the tax payments on this recapture a deferred tax liability has been recognized. This deferred tax liability is reduced by the taxes paid over EBITDA of E-Plus which were EUR 332 million in 2011 (2010: EUR 345 million). As per December 31, 2011, the deferred tax liability for the recapture amounted to EUR 519 million. Full recapture is expected to be realized in the course of 2013.
Koninklijke KPN fiscal unity
In 2006, KPN signed a compliance covenant (‘Handhavingsconvenant’) with the Dutch tax authorities to self-assess and transparently discuss KPN’s current and potential future tax issues. A few issues were outstanding at December 31, 2011, of which the deductibility of the loss of approximately EUR 110 million relating to the liquidation of a foreign entity and the timing of the deductibility of cost regarding the tender of outstanding bonds of approximately EUR 90 million are by far the most significant. KPN regards the liquidation loss as tax deductible which has not been accepted by the tax authorities. KPN has recorded the cost of the tender at once whereas the tax authorities are of the opinion that the cost should be spread over the lifetime of the new bonds. No tax receivable for the potential deductibility of the liquidation loss has been recognized nor any accrual for the other outstanding issues.
In 2011, KPN has reached an agreement with the Dutch tax authorities with regard to the application of the so called innovation tax facilities.
Innovation tax facilities are facilities under Dutch corporate income tax law whereby profits attributable to innovation are taxed at an effective rate of 5%. The agreement has retroactive effect to 1 January 2007. The application of the innovation tax facilities resulted in a one-off benefit of EUR 118 million mainly reflecting the period 2007 to 2010. KPN’s effective tax rate in The Netherlands was reduced from the statutory tax rate of 25% to approximately 20% in the year 2011 as a result of the application of the innovation tax facilities.
E-Plus
In Germany, the income tax consists of trade tax (‘Gewerbesteuer’) and corporate tax (‘Körperschaftssteuer’). E-Plus has considerable loss carry forwards for both trade tax and corporate tax. For tax purposes, certain past impairments of goodwill and licenses were not recognized and therefore are amortized over the remaining useful lives (deductible temporary differences). In Germany, taxable income in a certain year, exceeding EUR 1 million, can only be offset for 60% against tax loss carry forwards. Trade tax and corporate tax is payable over the remaining 40% of taxable income. Information about the available tax loss carry forwards is given on page 101.
At December 31, 2011, a deferred tax asset (DTA) of EUR 1,710 million was recognized of which EUR 801 million relates to estimated future tax savings due to available tax loss carry forwards and EUR 909 million for estimated future tax savings due to the realization of temporary differences. E-Plus determines the DTA by estimating future taxable income, taking into account various uncertainties in future cashflows.
Other entities
There are several other entities in the Netherlands which are separately liable for income taxes. In most other countries in which KPN and Getronics operate, tax loss carry forwards are available and therefore no income tax is payable except when minimum taxation rules are applicable.
98
Consolidated Financial Statements
Notes to the Consolidated Statement of Income
Income tax expense
Amounts in millions of EUR 2011 2010
Current tax −94 −276
Changes in deferred taxes −128 −232
Income tax benefit/(charge) −222 −508
The reconciliation from the Dutch statutory tax to the effective tax rate is explained in the table below.
Amounts in millions of EUR 2011 2010
Profit before income tax 1 1,795 2,334
Taxes at Dutch statutory tax rates 2 −449 −595
Tax rate differences of foreign operations 3 −51 −53
Non-taxable income and non-deductible expenses 4 −80 −31
Change in Dutch statutory tax rate 5 – 18
Innovation tax facilities 7 197 –
(De)recognition of deferred tax positions 6:
– related to prior years 203 193
– related to the current year −5 −17
Other −37 −23
Income tax benefit/(charge) −222 −508
Effective tax rate 12.4% 21.8%
1) Excluding the share in profits of associates and joint ventures.
2) Taxes at Dutch statutory tax rates are calculated on the basis of profit before income tax (excluding the share of profits of associates and joint ventures) and the applicable Dutch corporate income tax rate of 25% in 2011 and 25.5% in 2010.
3) Tax rate differences of foreign operations reflect the impact of different tax rates in the fiscal jurisdictions in which KPN operates. In 2011 and 2010, the corporate tax rates amounted to 15.8% in Germany, 34% in Belgium and 40% in the United States. The German trade tax rate was 15.6%.
4) Non-taxable income and non-deductible expenses represent adjustments for income not subject to taxation.
5) Relates to deferred taxes in the Netherlands. The Dutch statutory tax rate was decreased from 25.5% to 25.0% as of January 1, 2011.
6) (De)recognition of deferred tax positions reflects the effects of valuation or non-valuation of tax loss carry forwards and deductible temporary differences.
The amount related to prior years is mainly attributable to E-Plus.
7) In 2011, KPN has reached an agreement with the Dutch tax authorities with regard to the application of the so called innovation tax facilities.
The agreement has retroactive effect to January 1, 2007 resulting in a one-off benefit of EUR 118 million mainly reflecting the period 2007 to 2010.
99
Consolidated Financial Statements
KPN | Annual Report 2011 Notes to the Consolidated Statement of Income
Deferred tax assets and liabilities
Amounts in millions of EUR December 31, 2011 December 31, 2010
Deferred tax assets 1,831 1,918
– of which: to be recovered after 12 months 1,805 1,820
– of which: to be recovered within 12 months 26 98
Deferred tax liabilities 793 956
– of which: to be realized after 12 months 412 561
– of which: to be realized within 12 months 381 395
Deferred tax assets and liabilities 1,038 962
Depending on future taxable results, a part of deferred tax assets relating to tax loss carry forwards now considered to be recoverable after 12 months may be recoverable in the short term, whereas, tax loss carry forwards now considered to be recoverable within 12 months may be recoverable in the long term.
Deferred tax assets
Deductible temporary differences Tax loss carry
forwards Goodwill Other
intangibles 3 Pension
provisions Other 2
Offset against deferred tax
liabilities Total
Balance as of January 1, 2010 1,101 378 465 117 423 −349 2,135
Exchange differences – – – 1 −1 – –
Income statement benefit/
(charge) −38 −169 14 −10 91 – −112
Change in tax rates −2 – – −2 −6 – −10
Tax charged to equity – – – – −8 – −8
Reclassification – – – – – −87 −87
Balance as of
December 31, 2010 1 1,061 209 479 106 499 −436 1,918
Exchange differences 1 – – – –1 – −
Income statement benefit/
(charge) 4 −144 45 −33 −15 114 – −33
Change in tax rates – – – – – – –
Tax charged to equity – – – – −27 – −27
Reclassification 6 – – – −2 −26 −22
Transferred to held for sale – – – −3 −4 2 −5
Balance as of
December 31, 2011 1 924 254 446 88 579 −460 1,831
1) At December 31, 2011, deferred tax assets of EUR 1,834 million and EUR 897 million were not recognized for loss carry forwards and deductible temporary differences respectively.
2) Other deductible temporary differences at December 31, 2011 includes property, plant and equipment of EUR 327 million (2010: EUR 273 million), revenue recognition of EUR 16 million (2010: EUR 32 million), software of EUR 52 million (2010: EUR 41 million) and deferral of expenses for fiscal purposes of EUR 33 million (2010: EUR 61 million).
3) Mainly relates to UMTS licenses in Germany.
4) In the course of 2011 a restructuring took place of the Dutch operations of Getronics as a result of which these loss carry forwards were utilized and higher amortizable assets (goodwill) were recognized.
Deferred tax charged to equity relates mainly to movements in the hedge reserve.
100
Consolidated Financial Statements
Notes to the Consolidated Statement of Income
Deferred tax liabilities
Taxable temporary differences Deferred liability
due to losses German permanent
establishment Software
development Accelerated
depreciation 1 Other 2 Offset against
deferred tax assets Total
Balance as of January 1, 2010 1,213 65 56 290 −349 1,275
Income statement charge – 3 150 −16 – 137
Tax payable due to
E-Plus loss recapture −345 – – – – −345
Change in tax rate −17 −1 −4 −5 – −27
Changes in consolidation – – – 5 – 5
Reclassification – – 11 −13 −87 −89
Balance as of December 31, 2010 851 67 213 261 −436 956
Income statement charge – 22 118 −44 – 96
Tax payable due to
E-Plus loss recapture −332 – – – – −332
Change in tax rate – −2 2 − – –
Changes in consolidation – – – 3 – 3
Reclassification – – – – −26 −26
Transfer to current tax – 166 −48 −22 – 96
Transferred to held for sale – – – −2 2 –
Balance as of December 31, 2011 519 253 285 196 −460 793
1) Relates to Property, plant and equipment in the Netherlands
2) Other taxable temporary differences at December 31, 2011, includes intangible fixed assets of EUR 76 million (2010: EUR 155 million), property plant and equipment of EUR 35 million (2010: EUR 51 million) and provisions for early retirement and pension benefits of EUR 64 million (2010: EUR 64 million).
Tax loss carry forwards
December 31, 2011 December 31, 2010
Tax loss carry forwards Recognized deferred
tax assets Tax loss carry forwards Recognized deferred tax assets
Koninklijke KPN – corporate tax 1 117 9 480 97
KPN Group Belgium – corporate tax 228 83 328 111
E-Plus – trade tax 2 2,021 139 2,273 186
E-Plus – corporate tax 2 14,375 662 14,331 636
Getronics 3 24 – 195 1
Other 178 31 226 30
Total 16,943 924 17,833 1,061
1) The tax loss carry forwards are pre-consolidation losses (‘voorvoegingsverliezen’) limited in their use as such losses may only be compensated by taxable income generated by the specific company itself. The amount as per December 31, 2010 included tax loss carry forwards of the Dutch operations of Getronics of approximately EUR 327 million. In the course of 2011 a restructuring took place as a result of which these loss carry forwards were utilized and higher amortizable assets were recognized.
2) The loss carry forwards of trade tax and corporate tax can be used to offset future taxable income without any time limit. However, taxable income exceeding EUR 1 million in a certain year can only be offset for 60% against tax loss carry forwards. Trade tax and corporate tax have to be paid over the remaining 40% of taxable income. The available loss carry forwards were revised following a re-assessment in 2010 of tax positions of prior years for which tax returns have been filed but not yet agreed upon by the German tax authorities.
3) The amount of tax loss carry forwards mainly relates to the operations in the United Kingdom and Germany.
Recognized deferred tax assets reflect management’s estimate of realizable amounts. The amounts of tax loss carry forwards are subject to assessment by local tax authorities.
101
Consolidated Financial Statements
KPN | Annual Report 2011 Notes to the Consolidated Statement of Income
The expiration of the available tax loss carry forwards and recognized tax assets at December 31, 2011 is as follows:
Tax loss carry forwards Maximum
deferred tax asset Recognized deferred tax asset
2012 19 5 1
2013 14 3 1
2014 102 40 28
2015 14 4 2
2016 19 5 5
Later 118 29 –
Total limited 286 86 37
Unlimited 1 16,657 2,672 887
Total 16,943 2,758 924
1) Including trade tax and corporate tax at E-Plus.
The expiration of the available tax loss carry forwards and recognized tax assets at December 31, 2010 is as follows:
Tax loss carry forwards Maximum
deferred tax asset Recognized deferred tax asset
2011 60 15 5
2012 105 26 26
2013 37 10 2
2014 106 41 25
2015 17 4 2
Later 356 91 64
Total limited 681 187 124
Unlimited 1 17,152 2,792 937
Total 17,833 2,979 1,061
1) Including trade tax and corporate tax at E-Plus.