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Deferred tax assets and liabilities
 12 Months Ended
Dec. 31, 2022
Deferred tax assets and liabilities  
Deferred tax assets and liabilities

23 Deferred tax assets and liabilities

(€ million)
December 31, 2022

December 31, 2021
Deferred tax liabilities before offsetting
9,315

10,668
Deferred tax assets available for offset
(4,221 )
(5,833 )
Deferred tax liabilities
5,094

4,835
Deferred tax assets before offsetting (net of accumulated write-down provisions)
8,790

8,546
Deferred tax liabilities available for offset
(4,221 )
(5,833 )
Deferred tax assets
4,569

2,713


The most significant temporary differences giving rise to net deferred tax assets and liabilities are disclosed below:

(€ million)
Carrying amount at December 31, 2022

Carrying amount at December 31, 2021
Deferred tax liabilities
 

 
Accelerated tax depreciation
6,707

7,346
Derivative financial instruments
788

916
Difference between the fair value and the carrying amount of assets acquired
288

408
Site restoration and abandonment (tangible assets)
276

166
Leasing 
162

1,076
Application of the weighted average cost method in evaluation of inventories
52

87
Other
1,042

669
 
9,315

10,668
Deferred tax assets, gross
 

 
Carry-forward tax losses
(6,752 )
(7,374 )
Site restoration and abandonment (provisions for contingencies)
(1,986 )
(2,400 )
Timing differences on depreciation and amortization
(1,710 )
(2,354 )
Impairment losses
(1,490 )
(1,095 )
Accruals for impairment losses and provisions for contingencies
(1,246 )
(1,417 )
Leasing
(182 )
(1,091 )
Employee benefits
(161 )
(155 )
Unrealized intercompany profits
(68 )
(71 )
Derivative financial instruments
(60 )
(343 )
Over/Under lifting 
(59 )
(219 )
Other
(1,246 )
(631 )
 
(14,960 )
(17,150 )
Accumulated write-downs of deferred tax assets
6,170

8,604
Deferred tax assets, net
(8,790 )
(8,546 )


The following table summarizes the changes in deferred tax liabilities and assets:


(€ million)
Deferred tax liabilities before offsetting

Deferred tax assets before offsetting,
gross

Accumulated
write-downs of deferred tax
assets

Deferred tax assets before offsetting net of accumulated write-down provisions
Carrying amount at December 31, 2021
10,668

(17,150 )
8,604

(8,546 )
Additions
1,176

(2,215 )
464

(1,751 )
Deductions
(1,351 )
2,532

(2,409 )
123
Changes with effect to OCI
382

(147 )
 

(147 )
Currency translation differences
611

(610 )
165

(445 )
Changes in the scope of consolidation
(1,951 )
2,279

(549 )
1,730
Other changes
(220 )
351

(105 )
246
Carrying amount at December 31, 2022
9,315

(14,960 )
6,170

(8,790 )
Carrying amount at December 31, 2020
8,581

(16,231 )
9,065

(7,166 )
Additions
1,977

(1,783 )
270

(1,513 )
Deductions
(765 )
1,804

(863 )
941
Currency translation differences
683

(682 )
186

(496 )
Other changes
192

(258 )
(54 )
(312 )
Carrying amount at December 31, 2021
10,668

(17,150 )
8,604

(8,546 )


Carry-forward tax losses amounted to €25,932 million, of which €19,656 million can be carried forward indefinitely. Carry-forward tax losses were €14,000 million and €11,932 million at Italian subsidiaries and foreign subsidiaries, respectively. Deferred tax assets gross of accumulated write-downs recognized on these losses amounted to €3,360 million and €3,392 million, respectively.

Italian taxation law allows the carry-forward of tax losses indefinitely. Foreign taxation laws generally allow the carry-forward of tax losses over a period longer than five years, and in many cases, indefinitely. A tax rate of 24% was applied to tax losses of Italian subsidiaries to determine the portion of the carry-forwards tax losses. The corresponding average rate for foreign subsidiaries was 28.4%.

Accumulated write-downs of deferred tax assets related to Italian companies for €3,951 million and non-Italian companies for €2,219 million.

The reduction of accumulated write-downs of €2,434 million was primarily driven by an improved profitability outlook at Italian subsidiaries leading to the recognition of higher deferred tax assets in connection with expected higher taxable earnings.

Taxes are also described in note 33 – Income taxes.