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INCOME TAX (Tables)

12 Months Ended

Dec. 31, 2024

The domestic (France) and foreign components of our income before income tax are as follows:

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 tax losses carried forward amounting $258 million at December 31, 2024 and the associated valuation allowance

of $40 million was attributable to the following:

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

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

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: