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Tax
12 Months Ended
Dec. 31, 2025
Major components of tax expense (income) [abstract]  
Tax 8. Tax
Tax on profit for the year
United Kingdom
Other jurisdictions
Total
2025
2024
2023
2025
2024
2023
2025
2024
2023
$m
$m
$m
$m
$m
$m
$m
$m
$m
Current taxa
Current period
15
24
16
306
292
245
321
316
261
Adjustments in respect of prior periods
2
(3)
12
(1)
12
17
24
16
303
292
257
320
316
273
Deferred tax
Origination and reversal of temporary
differences
12
11
1
(39)
(56)
(21)
(27)
(45)
(20)
Changes in tax rates and tax laws
2
2
Adjustments to unprovided or
unrecognised deferred taxb
21
5
21
5
Adjustments in respect of prior periods
6
(2)
1
(5)
(1)
1
(2)
18
9
2
(23)
(56)
(15)
(5)
(47)
(13)
Income tax charge for the yearc
35
33
18
280
236
242
315
269
260
a.Includes $6m (2024: $2m, 2023: $nil) in respect of taxes arising under the Pillar Two framework.
b.In 2025, relates to tax arising following the completion of an intragroup restructuring.
c.‘Other jurisdictions’ includes $205m (2024: $169m, 2023: $172m) in respect of US taxes.
8. Tax continued
The income tax charge includes the following exceptional items:
2025
2024
2023
Current
tax
Deferred
tax
Current
tax
Deferred
tax
Current
tax
Deferred
tax
$m
$m
$m
$m
$m
$m
Tax on operating exceptional itemsa
4
1
(3)
(4)
Exceptional tax chargeb
(34)
13
(16)
(7)
a.Comprises the tax impacts of the operating exceptional items in note 6.
b.Comprises a $34m current tax charge and a $34m deferred tax credit, both in respect of tax that arose on the acquisition of Holiday Inn in 1990,
and a $21m deferred tax charge following the completion of an intra-group restructuring transaction, which otherwise has had no impact on the
consolidated financial statements. These are presented as exceptional due to their size and non-recurring nature.
Reconciliation of tax charge
2025
2024
2023
%
%
%
Tax at UK blended rate
25.0
25.0
23.5
Tax credits
(0.5)
(0.6)
(0.5)
System Funda
(0.1)
1.2
(1.3)
Foreign exchange losses/(gains)
(0.6)
1.0
(1.0)
Other permanent differencesb
(0.5)
0.9
Non-recoverable foreign taxes
3.0
2.4
1.3
Net effect of different rates of taxc
0.4
1.5
1.5
Effect of substantive enactment of UAE tax rates and lawsd
(0.9)
Effect of changes in other tax rates and laws
0.2
Items on which deferred tax arose but where no deferred tax is recognisede
0.2
0.2
0.2
Effect of adjustments to unprovided or unrecognised deferred taxesf
1.9
0.5
Adjustments to the tax charge in respect of prior periodsg
(0.2)
1.3
29.3
30.0
25.7
a.The System Fund is, in general, not subject to taxation.
b.Includes (0.8)%pts (2024: (1.0)%pts, 2023: (0.6)%pts) in respect of the US Foreign-Derived Intangible Income regime.
c.Includes 1.1%pts (2024: 1.2%pts, 2023: 1.3%pts) driven by the relatively high blended US rate, which includes US Federal and State taxes.
d.During 2023, law implementing a new corporate income tax regime was substantively enacted in the UAE. This resulted in the recognition
of a deferred tax asset of $9m in the UAE. Absent further law change, this benefit is not likely to reoccur.
e.Predominantly in respect of losses arising in the year.
f.Adjustments relating to estimated recoverable deferred tax assets. In 2025, relates to a deferred tax charge following the completion of an intra-group
restructuring transaction. In 2023, included 0.7%pts relating to the provision of previously unprovided deferred tax liabilities which arise on temporary
differences in subsidiaries.
g.Relates to the finalisation of tax returns, activity from tax authorities such as tax audits and the reassessment of provisions for uncertain tax positions.
Factors that may affect the future tax charge
Many factors will affect the Group’s future tax rate, the main ones being future legislative developments, future profitability
of underlying subsidiaries and resolution of tax uncertainties.
In 2021, the OECD made proposals for worldwide tax reform under a two ‘pillar’ system – Pillar One and Pillar Two.
Pillar One (broadly, the reallocation of certain taxing rights to countries where customers are located) has not been enacted in
any jurisdiction and, in any event, the Group would not expect to be impacted. There has been no substantial progress by the
OECD on the Pillar One rules and there is no certainty as to whether these will be ever enacted.
Pillar Two seeks to impose a global minimum tax, essentially establishing a floor on corporate tax competition by ensuring a large
multinational enterprise is subject to tax in each jurisdiction at a 15% effective minimum tax rate. Pillar Two rules are in effect for
the Group and the Group’s Pillar Two liability for 2025 is estimated to be $6m. The administration and compliance behind the
rules are burdensome and the Group will rely on transitional ‘safe harbour’ exemptions which remove the need to prepare full
calculations for Pillar Two for qualifying territories. The OECD agreed in January 2026 that these transitional arrangements would
be extended a further year, until the end of 2027, and announced a permanent safe harbour that will replace it. Based upon this
announcement, the Group expects that it will be able to rely on the permanent safe harbour for a number of key jurisdictions,
such as the US and China where the Group’s blended effective tax rate exceeds 25%, and therefore considers the likelihood of
material future Pillar Two taxes arising to be low, based upon the current profile of the Group’s business. The Group continues
to monitor external tax developments in this area, particularly as the new permanent safe harbour passes through the
legislative process.
8. Tax continued
Tax paid
Total tax paid (net of refunds) of $307m (2024: $309m) is entirely in respect of operating activities. This comprises taxes paid
directly by Group entities to taxing authorities and taxes withheld at source in respect of fees payable to the Group. Taxes
withheld at source are paid by hotel owners to their local taxing authorities on behalf of the Group. The table below shows
the territories to whom taxes are directly paid by the Group which exceed $5m in the current or comparative periods, in
addition to the UK, the Group’s headquarter jurisdiction. The increase between 2023 and 2024 is predominantly driven by
the corresponding increase to Group profitability and movement in deferred taxes. During 2025, exceptional tax of $34m
was paid without which there would have been a year-on-year decrease in taxes paid, as a result of tax reforms in the US.
2025
2024
2023
$m
$m
$m
Chinaa
13
11
5
Japana
9
3
3
Mexicob
8
5
3
Singaporea
9
7
4
United Kingdomb
10
10
8
United Statesb
194
220
171
Other jurisdictions
17
15
12
260
271
206
Taxes withheld at source
47
38
37
Tax paid per cash flow
307
309
243
Analysed as:
Exceptional tax paidc
34
Other
273
309
243
307
309
243
a.Tax payments are typically based upon the previous year’s profits.
b.Tax payments are typically based upon the current year’s profits.
c.Exceptional tax paid of $34m in 2025 relates to the settlement of a tax liability in the United States which originally arose as a result of the acquisition
of Holiday Inn in 1990 and became due for payment in 2025. There was no net impact on the tax charge for any year presented. The payment is
classified as an exceptional cash flow due to its size and nature.
A reconciliation of tax paid to the current tax charge in the Group income statement is as follows:
2025
2024
2023
$m
$m
$m
Current tax charge in the Group income statement
320
316
273
Current tax charge/(credit) in the Group statement of comprehensive income
2
(3)
(6)
Current tax credit taken directly to equity
(15)
(6)
(5)
Total current tax charge
307
307
262
Movements to tax contingenciesa
(1)
(4)
(2)
Timing differences of cash tax paid and foreign exchange differences
1
6
(17)
Tax paid per cash flow
307
309
243
a.Tax contingency movements are included within the current tax charge but do not impact cash tax paid in the year. Settlements of tax contingencies
are included within cash tax paid in the year but not recorded in the current year tax charge.
8. Tax continued
Deferred tax
Property,
plant,
equipment
and
software
Application
fees
Deferred
gains
on loan
notesa
Associates
Lossesb
Deferred
compensation
and employee
benefits
Deferred
revenuec
Research and
development
Intangible
assets
excluding
software
Other
short-term
temporary
differencesd
Total
$m
$m
$m
$m
$m
$m
$m
$m
$m
$m
$m
At 1 January 2024
(30)
42
(34)
(60)
76
95
15
(46)
8
66
Group income
statement
21
1
(7)
9
30
18
(14)
(11)
47
Group statement of
comprehensive income
(3)
(13)
(16)
Group statement of
changes in equity
9
9
Exchange and other
adjustments
(1)
(1)
(2)
At 31 December 2024
(9)
42
(34)
(59)
65
113
30
33
(60)
(17)
104
Group income
statement
(1)
1
34
1
8
19
(17)
(14)
(26)
5
Group statement of
comprehensive income
14
14
Group statement of
changes in equity
(6)
(6)
Exchange and other
adjustments
2
5
3
2
12
At 31 December 2025
(8)
43
(58)
70
118
49
16
(72)
(29)
129
a.In 2025, movement is in respect of tax arising on the acquisition of Holiday Inn in 1990. This is included within the exceptional tax charge.
b.Wholly in respect of revenue losses.
c.The movements in 2024 arose as a result of a revised agreement with the IHG Owners Association (see note 3) and deferred revenue in respect
of co-branding agreements.
d.Primarily in respect of contract costs, right-of-use assets, unrealised foreign exchange and expected credit losses on trade receivables, none of
which has a balance exceeding $20m.
The analysis of the deferred tax balance after considering the offset of assets and liabilities within entities where there is a
legal right to do so and an analysis of the deferred tax balance showing all territories with balances greater than $10m in either
the current or prior year are as follows:
2025
2024
$m
$m
Deferred tax assets
146
122
Deferred tax liabilities
(17)
(18)
129
104
Analysed as:
United Arab Emirates
13
12
United Kingdom
92
99
United States
33
Other
(9)
(7)
129
104
A deferred tax asset of $4m (2024: $3m) has been recognised in legal entities which have made a loss in the current or the
previous year.
8. Tax continued
Recoverability of UK deferred tax assets
The Group has recognised deferred tax assets of $92m (2024: $99m) in the UK. The major components are revenue losses
of $65m (2024: $62m) and tax depreciation of $30m (2024: $32m), reduced by a deferred tax liability of $19m (2024: $13m) on
past tax deductions in respect of intellectual property. The losses have arisen by identifiable non-recurring events, for example
special contributions into a former Group pension scheme and the impact of Covid-19, absent which, the UK tax group would
have been profitable, and there has been a history of loss usage since the Covid-19 restrictions eased. The losses do not expire,
although they can only be offset against 50% of annual UK taxable profits.
Unrecognised deferred tax assets
The Group does not recognise deferred tax assets if it cannot anticipate being able to offset them against existing deferred tax
liabilities or against future profits or gains.
The total unrecognised deferred tax position is as follows:
Gross
Unrecognised deferred
tax
2025
2024
2025
2024
$m
$m
$m
$m
Revenue losses
480
432
84
75
Capital losses
630
580
158
146
1,110
1,012
242
221
Tax credits
61
46
61
46
Othera
17
22
4
7
1,188
1,080
307
274
a.Primarily relates to costs incurred for which tax relief has not been obtained.
There is no expiry date to any of the above unrecognised assets other than for the losses and tax credits as shown in the
table below:
Gross
Unrecognised deferred
tax
2025
2024
2025
2024
Expiry date
$m
$m
$m
$m
2025
11
2
2026
6
7
1
1
2027
6
7
1
1
2029
10
10
10
10
2032
15
15
15
15
After 2032
34
21
34
21
Unprovided deferred tax liabilities
No deferred tax liability has been provided in respect of $42m (2024: $517m) of temporary differences relating to subsidiaries
(comprising undistributed earnings and inherent gains and losses).
Uncertain tax positions
Current tax payable includes $11m (2024: $9m) in respect of uncertain tax positions, with the largest single item not exceeding
$3m (2024: $3m). There are no amounts recognised in relation to uncertain tax positions within deferred tax in either the current
or prior year.
The Group’s most material territories for tax are the US and the UK, and the Group has now agreed all US federal tax returns up
to and including 2020. The US Internal Revenue Service is conducting routine audits of the 2021 and 2022 US federal tax return
periods. The Group considers the risk of material adjustment to be low. In the UK, the Group has agreed all UK Corporation Tax
returns for periods up to 2023.