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INCOME TAX
 12 Months Ended
Dec. 31, 2024
Income Tax Disclosure [Abstract]  
INCOME TAX NOTE 7 - INCOME TAX
The domestic (France) and foreign components of our income before income tax are as follows:
Year ended December 31,
(in millions of U.S. dollar)
2024
2023
2022
Domestic (France)
144
179
88
Foreign
(9)
53
62
Income before tax
135
232
150
The reconciliation of the French statutory income tax rate to the Group’s effective income tax rate is as follows:
Year ended December 31,
(in millions of U.S. dollar)
2024
2023
2022
Income before tax
135
232
150
Statutory tax rate applicable to the parent company
25.8%
25.8%
25.8%
Income tax expense calculated at statutory tax rate
(35)
(60)
(39)
Effect of foreign tax rate (A)
(1)
3
4
Investment in subsidiaries (B)
(1)
11
(1)
Changes in valuation allowance (C)
(34)
(7)
202
Change in tax laws and rates (D)
—
(9)
—
Prior year adjustments
(1)
(5)
4
BEAT Tax
(2)
(3)
(2)
Other
(1)
(5)
(3)
Income tax (expense) / benefit
(75)
(75)
165
Effective income tax rate
55.6%
32.3%
(110.0)%
(A)For the years ended December 31, 2024, 2023 and 2022, the effect of foreign tax rate resulted from the geographical mix of our pre-tax
results.
(B)For the year ended December 31, 2023, the effect of investment in subsidiaries mainly relates to the recognition of CTA reserves linked
to divestitures that occurred in 2023.
(C)For the year ended December 31, 2024, the changes in valuation allowance mainly relates to the deferred tax assets of our operating
entities in Germany as management determined that it was more likely than not that these DTAs would not be used in a foreseeable
future. In making this determination, management considered all available positive and negative evidence. For the year ended
December 31, 2023, the changes in valuation allowance mainly related to the deferred tax assets in Switzerland, Mexico and China. For
the year ended December 31, 2022, the changes in valuation allowance mainly related to one of our main operating entities in the
United States for $202 million as management determined that it was more likely than not that future earnings will be sufficient to
realize these deferred tax assets. In making this determination management considered all available positive and negative evidence
including historical results as well as forecasted profitability supported by revised projections from the Group’s latest long-term plan.
(D)For the year ended December 31, 2023, the changes in tax laws and rates related mainly to the change of composite tax rate in the
United States tax jurisdiction.
The Group has reviewed its corporate structure in light of the introduction of Pillar Two Model Rules in the jurisdictions
where it operates based on the most recent tax filings and financial statements. Based on this assessment, the Group has determined
that it is not liable to Pillar Two “top-up” taxes for the year ended December 31, 2024.
The components of our income tax provision are as follows:
Year ended December 31,
(in millions of U.S. dollar)
2024
2023
2022
Domestic (France)
(28)
(42)
(11)
Foreign
(16)
(16)
(12)
Current tax expense
(44)
(58)
(23)
Domestic (France)
(9)
—
(22)
Foreign
(22)
(17)
210
Deferred tax (expense) / benefit
(31)
(17)
188
Income tax (expense) / benefit
(75)
(75)
165
Unrecognized Tax Benefits
As of December 31, 2024, and 2023, and 2022, the total amount of unrecognized benefits that, if recognized, would
affect the effective income tax rate in future periods based on anticipated settlement dates is $12 million, $16 million and $21
million, respectively. Our tax returns for certain past years are still subject to examination by taxing authorities in the various
countries where we operate.
Our reserves for unrecognized tax benefits, as well as reserves for interest and penalties were:
Year ended December 31,
(in millions of U.S. dollar)
2024
2023
2022
Unrecognized tax benefits at January 1,  (A)
16
21
21
Additions for tax position of the current year
2
2
1
Additions for tax position of prior years
—
4
4
Reductions for tax positions of prior years (B)
(5)
—
—
Settlements with tax authorities
(1)
(9)
—
Reductions for expiration of statute of limitations
—
(2)
(5)
Unrecognized tax benefits at December 31, (A)
12
16
21
(A)Including interest and penalties
(B)Excluding reduction for settlements with tax authorities
Our policy is to record interest and penalties related to unrecognized tax benefits in income tax (benefit) provision on our
consolidated statements of operations. As of December 31, 2024, 2023, and 2022, we accrued for interest and penalties of $0
million, $1 million, and $1 million, respectively.
Deferred Income Taxes
The following tables presents our net deferred income tax assets / (liabilities):
At December 31,
(in millions of U.S. dollar)
2024
2023
Net deferred income tax assets
311
337
Net deferred income tax liabilities
(39)
(35)
Net deferred taxes
272
302
The following table presents the components of deferred income tax assets and liabilities as of December 31, 2024 and 
December 31, 2023:
At December 31,
(in millions of U.S. dollar)
2024
2023
Deferred income tax assets
Tax losses carried forward
258
210
Long term assets
35
56
Pensions
76
90
Derivative valuation
10
5
Interest carried forward
52
38
Other (A)
54
70
Total deferred income tax assets
485
469
Less: valuation allowance (B)
(73)
(41)
Deferred income tax assets, net of valuation allowance
412
428
Deferred income tax liabilities
Long-term assets
(132)
(124)
Inventories
(8)
(2)
Other
—
—
Deferred income tax liabilities
(140)
(126)
(A)At December 31, 2024 and 2023, Other deferred income tax assets primarily related to temporary differences arising from provisions
and interest expense which will become tax-deductible in future periods.
(B)The following table summarizes changes in valuation allowance: 
(in millions of U.S. dollar)
2024
2023
2022
At January 1, 
41
50
258
Deduction
(1)
(19)
(209)
Addition
33
10
1
At December 31,
73
41
50
Some deferred tax assets in respect of temporary differences and unused tax losses were recognized without being offset
by deferred tax liabilities. In accordance with the accounting policies described in Note 1 of the Consolidated Financial
Statements (Judgments in applying accounting policies and key sources of estimation uncertainty), a detailed assessment was
performed on net deferred tax asset recovery at December 31, 2024 and 2023, with specific focus on tax jurisdictions with
unused tax losses carried forward. Management considered that the tax losses that generated the deferred tax assets were not
expected to be recurring and did not challenge the profitable long-term structure of its business model. In addition, tax planning
opportunities are available to increase the taxable profit and the use of the long-term limited and unlimited tax losses.
Management concluded that it was more likely than not that the net deferred tax balance of $272 million and $302 million at
December 31, 2024 and 2023, respectively, would be recoverable.
Based on the expected taxable income of the entities, the Group believed that it was more likely than not that a total of
$73 million at December 31, 2024, of unused tax losses and deductible temporary differences, would not be used.
Consequently, a valuation allowance was recognized for the corresponding deferred tax assets.
The tax losses carried forward amounting $258 million at December 31, 2024 and the associated valuation allowance
of $40 million was attributable to the following:
At December 31, 2024
(in millions of U.S. dollar)
Tax Losses
Carried Forward
Valuation
Allowance
Carryforward
Period
Earliest Year of
Expiration
Net operating loss
United States
142
—
Indefinite
—
United States
74
—
20 years
2032
France
4
(4)
Indefinite
—
Germany
12
(12)
Indefinite
—
Switzerland
15
(15)
7 years
2028
China
4
(4)
5 years
2025
Other
7
(5)
> 5 years or
indefinite
2027
Total
258
(40)