XML 44 R24.htm IDEA: XBRL DOCUMENT v3.21.2
Income Tax
12 Months Ended
Jun. 30, 2021
Income Tax [Abstract]  
Income Tax
17.
 
I
NCOME
 
TAX
 
 
Income tax provision
 
The table below presents
 
the components of (loss)
 
income before income taxes
 
for the years
 
ended June 30, 2021,
 
2020 and 2019:
2021
2020
2019
South Africa
$
(30,825)
$
(26,230)
$
(273,265)
United States
(6,686)
(8,984)
(23,479)
Liechtenstein
(810)
(17,519)
-
Other
32,702
(12,283)
(22,699)
Loss before income taxes
$
(5,619)
$
(65,016)
$
(319,443)
Presented below is the provision
 
for income taxes by location of
 
the taxing jurisdiction
 
for the years ended June 30, 2021,
 
2020
and 2019:
2021
2020
2019
Current income tax expense (benefit)
$
859
$
1,652
$
4,789
South Africa
866
1,552
3,689
United States
(75)
12
1,100
Other
68
88
-
Deferred taxation charge (benefit)
6,691
932
(8,917)
South Africa
(2,039)
653
(8,538)
United States
9,136
-
4
Other
(406)
279
(383)
Foreign tax credits generated – United States
10
72
(944)
Income tax provision (benefit)
$
7,560
$
2,656
$
(5,072)
There were
no
 
changes to the enacted tax rate in the years ended June 30, 2021, 2020 and 2019.
 
 
During the years
 
ended June 30, 2021, 2020 and 2019,
 
the Company incurred net operating losses through certain of it its South
African wholly-owned
 
subsidiaries and recorded a
 
deferred taxation benefit related to
 
these losses. However, the Company has
 
created
a valuation allowance for these net operating losses which reduced
 
the deferred taxation benefit recorded.
 
The Company incurred a net
 
capital gain, after the application
 
of capital loss carryforwards, related
 
to the internal restructuring
of a wholly-owned subsidiary during the year ended June 30, 2020. The Company also generated taxable capital gains during the year
ended June 30, 2020, related to the disposal of
 
FIHRST (refer to Note 23) and the sale
 
of DNI (refer to Note 8) but
 
utilized capital loss
carryforwards
 
to
 
reduce
 
the
 
capital
 
gains
 
on
 
these
 
transactions
 
to
 
zero
 
($
0
).
 
 
17.
 
INCOME
 
TAX
 
(continued)
 
 
Income tax provision (continued)
 
The Company calculated its Transition Tax liability as of June 30, 2018, and incurred a Transition Tax, before the application of
any foreign
 
tax credits,
 
of $
55.8
 
million, and
 
has no
 
liability after
 
the application
 
of generated
 
foreign tax
 
credits. During
 
the year
ended June 30,
 
2019, the Company
 
recorded the difference
 
of $
1.1
 
million between the Transition
 
Tax
 
liability of $
56.9
 
million and
the provisional
 
Transition
 
Tax
 
liability of
 
$
55.8
 
million in
 
current income
 
tax, United
 
States. During
 
the year
 
ended June 30,
 
2019,
the Company also included the
 
additional foreign tax credits utilized
 
of $
1.1
 
million against this Transition
 
Tax in foreign
 
tax credits
generated – United States.
 
 
A reconciliation
 
of income
 
taxes, calculated
 
at the
 
fully-distributed South
 
African income
 
tax rate
 
to the
 
Company’s
 
effective
tax rate, for the years ended June 30, 2021, 2020 and 2019, is as follows:
2021
2020
2019
Income taxes at fully-distributed South African tax rates
28.00
%
28.00
%
28.00
%
Movement in valuation allowance
(250.16)
%
1.64
%
(22.98)
%
Non-deductible items
(58.40)
%
(10.38)
%
(3.33)
%
Foreign tax rate differential
51.21
%
(4.17)
%
(0.07)
%
Capital gains differential
93.03
%
(1.59)
%
(1.46)
%
Prior year adjustments
1.77
%
(0.01)
%
(0.03)
%
Release from FCTR
-
 
-
 
(14.65)
%
-
 
-
 
Subpart F inclusions
-
 
-
 
(2.85)
%
-
 
-
 
Foreign tax credits
-
 
-
 
(0.08)
%
0.35
%
Taxation on deemed
 
dividends in the United States
-
 
-
 
-
 
-
 
1.45
%
Transition Tax
-
 
-
 
-
 
-
 
(0.34)
%
Income tax provision
(134.55)
%
(4.09)
%
1.59
%
Percentages included in the 2021, 2020 and 2019 columns
 
in the reconciliation of income taxes presented above are impacted by
the loss incurred
 
by the Company
 
during the
 
year ended
 
June 30, 2021,
 
2020 and
 
2019. For instance,
 
the income
 
tax provision
 
of $
7.6
 
million represents (
134.55
%) multiplied by the net loss before tax of $(
5,619
). Movement in the valuation allowance for the year
ended June
 
30, 2021,
 
includes allowances
 
created related
 
to net
 
operating losses
 
incurred during
 
the year.
 
Non-deductible items
 
for
the year ended June 30, 2021, includes the impact of the allowance for doubtful loans created.
 
The foreign tax rate differential relates
primarily to the difference between
 
the fully-distributed South African income
 
tax rate and
 
the rate used (
21
%) to measure the
 
deferred
tax
 
liability
 
created
 
related
 
to
 
the
 
fair
 
adjustment
 
to
 
the
 
Company’s
 
investment
 
in
 
MobiKwik
 
(refer
 
to
 
Note
 
8).
 
The capital
 
gains
differential
 
for the
 
year ended
 
June 30,
 
2021, represents
 
the impact
 
of the
 
reversal of
 
the deferred
 
tax liability
 
related to
 
one of
 
the
Company’s equity-accounted
 
investments following its impairment (refer to Note 8).
 
Movement in the valuation allowance
 
for the year ended
 
June 30, 2020,
 
includes allowances created related to
 
net operating losses
incurred during the year and
 
valuation allowances
 
created for a deferred tax
 
asset recorded related to the deconsolidation
 
of CPS and
other corporate
 
transactions. Release
 
from FCTR
 
for the
 
year
 
ended June
 
30, 2020,
 
relates to
 
the releases
 
from accumulated
 
other
comprehensive loss (refer to Note 14) that are not deductible for
 
tax purposes. Non-deductible items for the year ended June 30, 2020,
includes the option termination fee paid and the goodwill impairment
 
loss recognized.
 
Movement in the valuation allowance
 
for the year ended
 
June 30, 2019, includes
 
allowances created related to
 
net operating losses
incurred during the year and a valuation
 
allowance created for a deferred tax
 
asset recorded related to the DNI disposal
 
capital losses
generated (refer to Note
 
8) and the Cell C capital
 
loss following the fair
 
value adjustment (refer to Note
 
5). Non-deductible items for
the
 
year
 
ended
 
June
 
30,
 
2019,
 
includes
 
the
 
impairment
 
losses
 
recognized
 
related
 
to
 
goodwill
 
impaired.
 
 
17.
 
INCOME
 
TAX
 
(continued)
 
 
Deferred tax assets and liabilities
 
Deferred
 
income taxes
 
reflect the
 
temporary
 
differences
 
between
 
the financial
 
reporting and
 
tax bases
 
of assets
 
and
 
liabilities
using enacted tax rates
 
in effect for the
 
year in which
 
the differences are expected
 
to reverse. The
 
primary components of the
 
temporary
differences that gave rise to the Company’s
 
deferred tax assets and liabilities as of June 30, and their classification, were as follows:
June 30,
June 30,
2021
2020
Total
 
deferred tax assets
Capital losses related to investments
$
47,518
$
36,721
Net operating loss carryforwards
36,329
32,459
Foreign tax credits
32,737
32,799
Provisions and accruals
2,123
3,936
FTS patent
163
181
Other
654
815
Total
 
deferred tax assets before valuation allowance
119,524
106,911
Valuation
 
allowances
(118,777)
(106,433)
Total
 
deferred tax assets, net of valuation allowance
747
478
Total
 
deferred tax liabilities:
Intangible assets
100
171
Investments
10,354
1,755
Other
87
53
Total
 
deferred tax liabilities
10,541
1,979
Reported as
Long-term deferred tax assets
622
358
Long-term deferred tax liabilities
10,415
1,859
Net deferred income tax liabilities
$
9,793
$
1,501
Increase in total net deferred income tax liabilities
 
Capital losses related to investments
 
Capital losses as of June 30,
 
2021 and 2020,
 
comprises the capital loss arising from
 
the difference between the amount
 
paid for
Cell C in August 2017 and the its fair value as of the respective year end, of $
0.0
 
million, and difference between the amount paid for
CPS in 2004
 
and the its
 
fair value
 
as of the
 
respective year
 
end, of
 
$
0.0
 
million. The
 
change in capital
 
losses related
 
to investments
relates primarily to the impact of currency changes between the South Africa
 
Rand against the United States dollar.
 
 
Net operating loss carryforwards
 
Net operating loss carryforwards have increased due
 
to losses incurred by certain of the Company’s
 
subsidiaries and the impact
of currency changes between the South Africa Rand
 
against the United States dollar, which was partially offset by
 
net operating losses
carryforwards forfeited following the substantial liquidation of
 
certain of the Company’s subsidiaries.
 
 
Investments
 
Investment increased during the year
 
ended June 30, 2021,
 
primarily as a result
 
of the fair value
 
adjustments to the carrying
 
value
of MobiKwik (refer to Note 8).
 
Decrease in valuation allowance
 
At
 
June
 
30,
 
2021,
 
the
 
Company
 
had
 
deferred
 
tax
 
assets of
 
$
0.7
 
million
 
(2020:
 
$
0.5
 
million), net
 
of the
 
valuation
 
allowance.
Management believes,
 
based on
 
the weight
 
of available
 
positive and
 
negative evidence
 
it is
 
more likely
 
than not
 
that the
 
Company
will realize the benefits of these deductible differences, net of the valuation
 
allowance. However, the amount of the deferred
 
tax asset
considered realizable could be adjusted in the future if estimates of taxable
 
income are revised.
 
 
 
17.
 
INCOME
 
TAX
 
(continued)
 
 
Deferred tax assets and liabilities (continued)
 
Decrease in valuation allowance (continued)
 
At June
 
30, 2021,
 
the Company
 
had a
 
valuation allowance
 
of $
118.8
 
million (2020:
 
$
106.4
 
million) to
 
reduce its
 
deferred tax
assets to estimated
 
realizable value. The movement in
 
the valuation allowance for
 
the years ended
 
June 30, 2021
 
and 2020, is
 
presented
below:
Total
Capital losses
related to
investments
Net operating
loss carry-
forwards
Foreign tax
credits
Other
July 1, 2019
$
125,887
$
43,569
$
35,861
$
32,799
$
13,658
Charged to statement of operations
27,700
5,399
20,602
-
1,699
Reversed to statement of operations
(14,314)
(5,486)
(77)
-
(8,751)
Deconsolidation
(16,130)
-
(15,830)
-
(300)
Utilized
(3,896)
-
(3,632)
-
(264)
Foreign currency adjustment
(12,814)
(6,761)
(4,651)
-
(1,402)
June 30, 2020
106,433
36,721
32,273
32,799
4,640
Charged to statement of operations
16,376
3,532
13,264
-
(420)
Reversed to statement of operations
(14,840)
-
(13,687)
(62)
(1,091)
Utilized
(1,422)
-
(135)
-
(1,287)
Foreign currency adjustment
12,230
7,265
4,555
-
410
June 30, 2021
$
118,777
$
47,518
$
36,270
$
32,737
$
2,252
Net operating loss carryforwards and foreign tax credits
 
United States
 
Net operating
 
loss generated are
 
carried forward
 
indefinitely,
 
but the loss
 
carryforward
 
that may be
 
used against future
 
taxable
income is limited to 80% of taxable income before the net operating loss deduction.
 
In March 2020,
 
the Coronavirus Aid,
 
Relief and Economic
 
Security Act (the
 
“Cares Act”) was enacted.
 
The Cares Act, among
other items,
 
provides for
 
a temporary
 
repeal of
 
the 80 percent
 
net operating
 
loss limitation and
 
provides temporary
 
modifications to
the limitation on deductibility of business interest.
 
As of June 30, 2021, Net1 had net operating loss carryforwards that will expire,
 
if unused, as follows:
Year
 
of expiration
 
U.S. net
operating loss
carry
forwards
2024
$
775
Net1 had no net unused foreign tax credits that
 
are more likely than not to be realized as
 
of June 30, 2021 and 2020, respectively.
 
 
Uncertain tax positions
 
As of June 30, 2021 and 2020, the Company had
no
 
unrecognized tax benefits which would impact the Company’s
 
effective tax
rate.
 
The
 
Company
 
files
 
income
 
tax
 
returns
 
mainly
 
in
 
South
 
Africa,
 
Germany,
 
Hong
 
Kong,
 
India,
 
Malta,
 
the
 
United
 
Kingdom,
Botswana and in the U.S. federal jurisdiction. As of June 30, 2021, the Company’s South African subsidiaries are no longer subject to
income tax examination
 
by the South African
 
Revenue Service for periods
 
before June 30, 2017.
 
The Company is subject
 
to income
tax in other
 
jurisdictions outside South Africa,
 
none of which
 
are individually material to
 
its financial position, statement
 
of cash flows,
or results of operations.
 
The Company does not
 
expect the change related
 
to unrecognized tax benefits will
 
have a significant impact
on its results of operations or financial position in the next 12 months.