RE: Net Cash31 May 2023 17:46
Kistos's rationale sounds perfectly reasonable and I would hope that the 46.9m euro liability will never have to be paid.
However, we are dealing with politicians here.....sound reasoning is alien to them.
"In October 2022, the EU member states adopted Council Regulation (EU) 1854/2022, which required EU member states to introduce a Solidarity Contribution Tax for companies active in the oil, gas, coal and refinery sectors. The Dutch implementation of this solidarity contribution has been legislated by a retrospective 33% tax on 'surplus profits' realised during 2022, defined as taxable profit exceeding 120% of the average taxable profit of the four previous financial years. Companies in scope are those realising at least 75% of their turnover through the production of oil and natural gas, coal mining activities, refining of petroleum or coke oven products.
The Group believes that there is an argument that Kistos NL2 B.V. is out of scope of the regulations as, in its opinion, less than 75% of its turnover under Dutch GAAP (the relevant measure for Dutch taxation purposes) was derived from the production of petroleum or natural gas, coal mining, petroleum refining, or coke oven products. Furthermore, the Group understands the implementation of the tax, including its retrospective nature, is subject to legal challenges by other parties. However, as there is no history or precedent for this tax being audited or collected by the Dutch tax authorities, the Group has applied IFRIC 23, 'Uncertainty over Income Tax Treatments' and recorded a liability of €46.9 million relating to the Solidarity Contribution Tax in the current tax charge for the year. This is the single most likely amount of the charge if it becomes payable. The Group expects to get further certainty around this tax position in 2024."
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