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Income Taxes (Tables)

12 Months Ended

Dec. 31, 2023

Schedule of Domestic and Foreign Components of Loss from Continuing Operations before Income Taxes

The components of our earnings (loss) from continuing operations before income taxes are as follows:


	Year ended December 31,
	2023		2022		2021
	in millions

U.K.	$	(2,899.5)	$	(516.2)	$	12,922.0
The Netherlands	(805.4)		742.3		644.5
Belgium	653.9		1,000.4		404.7
Switzerland	(446.7)		(470.5)		(308.3)
Luxembourg	(195.6)		505.4		373.2
Ireland	(16.6)		178.3		39.5
U.S.	(4.7)		5.9		(3.7)
Intercompany activity with discontinued operations	—		(15.6)		(54.2)
Other	(9.6)		(5.8)		(16.9)
Earnings (loss) from continuing operations before income taxes	$	(3,724.2)	$	1,424.2	$	14,000.8

Schedule of Income Tax Expense Benefit (Expense)

Our income tax expense consists of:


	Current		Deferred		Total
	in millions

Year ended December 31, 2023:
Belgium	$	(100.9)	$	(64.9)	$	(165.8)
U.S. (a)	(68.0)		(28.4)		(96.4)
Switzerland	(0.3)		78.9		78.6
Luxembourg	—		44.3		44.3
The Netherlands	(16.9)		0.2		(16.7)
Ireland	3.6		2.5		6.1
U.K.	(0.1)		0.5		0.4
Other	(0.1)		—		(0.1)
Total income tax expense	$	(182.7)	$	33.1	$	(149.6)

Year ended December 31, 2022:
U.S. (a)	$	(51.8)	$	(133.0)	$	(184.8)
Luxembourg	(0.3)		(152.3)		(152.6)
Switzerland	0.6		87.2		87.8
Belgium	(87.7)		17.1		(70.6)
Ireland	(5.3)		10.5		5.2
The Netherlands	(1.7)		(0.8)		(2.5)
U.K.	(0.1)		0.8		0.7
Other	(0.1)		(2.0)		(2.1)
Total income tax expense	$	(146.4)	$	(172.5)	$	(318.9)

Year ended December 31, 2021:
U.K.	$	(0.4)	$	(319.5)	$	(319.9)
Belgium	(96.3)		16.2		(80.1)
U.S. (a)	(47.9)		(25.8)		(73.7)
Switzerland	(7.2)		63.5		56.3
Luxembourg	(0.4)		(49.5)		(49.9)
The Netherlands	(2.6)		(1.3)		(3.9)
Ireland	(0.7)		—		(0.7)
Other	0.4		(1.8)		(1.4)
Total income tax expense	$	(155.1)	$	(318.2)	$	(473.3)

_______________

(a) Includes federal and state income taxes. Our U.S. state income taxes were not material during any of the years presented.

Schedule of Income Tax Benefit (Expense) Reconciliation

Income tax expense attributable to our earnings (loss) from continuing operations before income taxes differs from the amounts computed using the applicable income tax rates as a result of the following factors:


	Year ended December 31,
	2023		2022		2021
	in millions

Computed “expected” tax benefit (expense) (a)	$	875.2	$	(270.6)	$	(2,660.2)
Basis and other differences in the treatment of items associated with investments in subsidiaries and affiliates (b)	(406.9)		(68.4)		84.0
Change in valuation allowances	(275.1)		(39.0)		(62.2)
Non-deductible or non-taxable foreign exchange results	(198.7)		267.3		218.0
Non-deductible or non-taxable interest and other expenses	(138.4)		(89.6)		(69.0)
International rate differences (c)	(13.3)		(147.1)		(92.4)
Tax benefit associated with technologies innovation (d)	6.5		22.1		25.8
Non-taxable gain on the U.K. JV Transaction	—		—		2,066.0

Recognition of previously unrecognized tax benefits	—		—		20.5
Other, net	1.1		6.4		(3.8)
Total income tax expense	$	(149.6)	$	(318.9)	$	(473.3)

_______________

(a)The statutory or “expected” tax rates are the U.K. rates of 23.5% for 2023 and 19.0% for 2022 and 2021. The 2023 statutory rate represents that blended rate in effect for the year ended December 31, 2023 based on the 19.0% statutory rate that was in effect for the first quarter of 2023 and the 25.0% statutory rate that was in effect for the remainder of 2023. Although we are domiciled in Bermuda, we have used the U.K. statutory rate as management believes it is more meaningful.

(b)Amounts reflect the net impact of differences in the treatment of income and loss items between financial reporting and tax accounting related to investments in subsidiaries and affiliates, including the effects of foreign earnings.

(c)Amounts reflect adjustments (either a benefit or expense) to the “expected” tax benefit (expense) for statutory rates in jurisdictions in which we operate outside of the U.K.

(d)Amounts reflect the recognition of the innovation income tax deduction in Belgium.

Schedule of Current And Noncurrent Deferred Tax Assets And Liabilities

The components of our net deferred tax liabilities are as follows:


	December 31,
	2023		2022
	in millions

Deferred tax assets (a)	$	83.6	$	233.8
Deferred tax liabilities (a)	(543.7)		(533.8)
Net deferred tax liabilities	$	(460.1)	$	(300.0)

_______________

(a)Our deferred tax assets and deferred tax liabilities are included within other assets, net, and other long-term liabilities, respectively, on our consolidated balance sheets.

The tax effects of temporary differences that give rise to significant portions of our deferred tax assets and deferred tax liabilities are presented below:


	December 31,
	2023		2022
	in millions

Deferred tax assets:
Net operating loss and other carryforwards	$	1,372.1	$	1,327.6
Investments	366.4		251.8
Lease liabilities	186.5		184.0
Debt and interest	185.2		175.7
Property and equipment, net	169.9		125.7
Derivative instruments	126.7		4.3
Share-based compensation	81.4		84.7
Other future deductible amounts	60.7		64.6
Deferred tax assets	2,548.9		2,218.4
Valuation allowance	(1,899.6)		(1,586.5)
Deferred tax assets, net of valuation allowance	649.3		631.9
Deferred tax liabilities:
Intangible assets	(272.9)		(336.7)
Property and equipment, net	(272.2)		(157.6)
Debt and interest	(266.4)		(91.1)
ROU assets	(177.2)		(177.1)
Derivative instruments	(70.8)		(155.3)
Other future taxable amounts	(49.9)		(14.1)
Deferred tax liabilities	(1,109.4)		(931.9)
Net deferred tax liabilities	$	(460.1)	$	(300.0)

Schedule of Operating Loss Carryforwards

The significant components of our tax loss carryforwards and related tax assets at December 31, 2023 are as follows:


	Tax loss carryforward		Related tax asset		Expiration date
Country	in millions

The Netherlands	$	2,599.3	$	670.6	Indefinite
Belgium	1,145.5		286.4		Indefinite
U.K.	767.7		191.9		Indefinite
Luxembourg	441.1		119.9		Various
Ireland	387.1		48.7		Indefinite
Switzerland	295.5		51.1		7 years
Other	9.9		3.5		Various
Total	$	5,646.1	$	1,372.1

Schedule of Unrecognized Tax Benefits Roll Forward

The changes in our unrecognized tax benefits for the indicated periods are summarized below:


	2023		2022		2021
	in millions

Balance at January 1	$	435.2	$	447.1	$	602.5
Additions for tax positions of prior years	8.5		—		12.9
Effects of business acquisitions	6.9		—		—
Reductions for tax positions of prior years	(5.9)		(11.2)		(170.0)
Settlements with tax authorities	(4.0)		—		—
Additions based on tax positions related to the current year	2.2		1.7		14.3
Foreign currency translation	1.5		(2.3)		(8.7)
Lapse of statute of limitations	—		(0.1)		(3.9)


Balance at December 31	$	444.4	$	435.2	$	447.1