XML 46 R15.htm IDEA: XBRL DOCUMENT v3.25.0.1
Tax expense/(benefit)
 12 Months Ended
Dec. 31, 2024
Tax Expenses [Abstract]  
Tax expense/(benefit)
7.
Tax expense/(benefit)
The following table summarizes Tax expense:
Years ended December 31,
2024
2023
2022
(€ million)
Current tax expense
€1,070
€3,405
€3,565
Deferred tax expense/(benefit)
(2,503)
559
(840)
Tax expense/(benefit) relating to prior periods(1)
(55)
(171)
4
Total Tax expense/(benefit)
€(1,488)
€3,793
€2,729
________________________________________________________________________________________________________________________________________________
(1) Tax expense/(benefit) relating to prior periods includes €372 million deferred tax expense, €173 million deferred tax expense and €161 million deferred tax expense for 2024,
2023 and 2022, respectively, primarily related to U.S. provision to return adjustments for prior year tax positions
Effective tax rate reconciliation
The applicable tax rate used to determine theoretical income taxes is the statutory rate of the jurisdiction in which
the Company is tax resident during each reported period. From 2021, as a result of the merger, Stellantis N.V. is tax resident
in the Netherlands. The reconciliation between the theoretical income tax and actual tax is calculated on the basis of the
Netherlands corporate income tax rate of 25.8 percent in 2024, 2023 and 2022, as follows:
Years ended December 31,
2024
2023
2022
(€ million)
Profit/(loss) before tax
€4,032
€22,418
€19,508
Income tax rate
25.8%
25.8%
25.8%
Theoretical income taxes
€1,040
€5,784
€5,033
Tax effect on:
Differences between foreign tax rates and the theoretical applicable tax rate and
tax holidays
8
(407)
(495)
Recognition and utilization of previously unrecognized deferred tax assets
(2,512)
(740)
(1,153)
Deferred tax assets not recognized and write-downs
442
—
47
Permanent differences
(5)
(470)
(406)
Tax credits
(531)
(299)
(221)
Withholding tax
57
44
21
Other differences
13
(119)
(97)
Total Tax expense/(benefit)
€(1,488)
€3,793
€2,729
Effective tax rate
-36.9%
16.9%
14.0%
The decrease in the effective tax rate to (36.9) percent in 2024 from 16.9 percent in 2023 is primarily related to non-
recurring €2.3 billion net tax benefit recorded in 2024 related to recognition of previously unrecognized Deferred tax assets in
Brazil.
We monitor the realizability of our deferred tax assets taking into account all relevant factors at each reporting
period. As of December 31, 2024, based on the relevant weight of positive and negative evidence, including the amount of
taxable income and cumulative earnings in recent years which is objective and verifiable, and consideration of our expected
future earnings, we concluded that it is probable that our Brazil deferred tax assets are realizable. As such, Deferred tax assets
of €2.3 billion were recognized.
Net deferred tax position
The Company recognizes the net amount as either Deferred tax assets or Deferred tax liabilities, to the extent
deferred taxes may be offset. Amounts recognized were as follows:
At December 31,
2024
2023
(€ million)
Deferred tax assets(1)
€4,371
€2,152
Deferred tax liabilities(1)
(4,507)
(4,784)
Total Net deferred tax assets/(liabilities)
€(136)
€(2,632)
The decrease in Net deferred tax liabilities was mainly due to an increase in Net deferred tax assets in Brazil for non-
recurring €2.3 billion net tax benefit recorded in 2024 related to recognition of previously unrecognized Deferred tax assets,
along with a decrease in net deferred tax liabilities in North America. See Note 2, Basis of preparation - Critical judgements
and use of estimates - Recoverability of deferred tax assets for additional information.
Changes in deferred tax position by nature
The significant components of Deferred tax assets and liabilities and their changes during the years ended
December 31, 2024 and 2023 were as follows:
At January 1,
2024
Recognized in
Consolidated
Income
Statement
Recognized in
Equity
Transferred
to Assets/
(Liabilities)
Held for Sale
Translation
differences and
Other
At December
31, 2024
(€ million)
Deferred tax liabilities arising on:
Accelerated depreciation
€(3,102)
€(304)
€—
€—
€(107)
€(3,513)
Capitalized development assets
(3,921)
471
—
—
27
(3,423)
Other Intangible assets and
Intangible assets with indefinite
useful lives
(3,869)
20
—
—
(185)
(4,034)
Right-of-use assets
(276)
(28)
—
—
(9)
(312)
Provision for employee benefits
(1,078)
(5)
66
—
(50)
(1,067)
Other
(1,045)
(24)
(47)
10
(94)
(1,200)
Total deferred tax liabilities
€(13,291)
€131
€19
€10
€(417)
€(13,548)
Deferred tax assets arising on:
Provisions
4,468
467
—
—
(22)
4,914
Provision for employee benefits
1,953
214
(13)
—
142
2,296
Lease liabilities
336
48
—
—
15
399
Impairment of tangible and
intangible assets
877
(232)
—
—
(13)
632
Inventories
444
(54)
—
—
(3)
386
Allowances for doubtful
accounts
59
15
—
—
(6)
69
Provision for buy back
153
(35)
—
—
33
151
Other
2,982
(203)
(109)
—
(136)
2,534
Total deferred tax assets
€11,272
€220
€(122)
€—
€10
€11,381
Unrecognized deferred tax assets
on temporary differences(1)
(3,377)
608
12
—
100
(2,657)
Deferred tax assets arising on tax
loss carry-forwards
9,069
214
—
—
(501)
8,782
Unrecognized deferred tax assets
on tax loss carry-forwards
(6,305)
1,704
—
—
507
(4,094)
Total Net deferred tax assets/
(liabilities)
€(2,632)
€2,878
€(91)
€10
€(301)
€(136)
________________________________________________________________________________________________________________________________________________
(1) Unrecognized deferred tax assets on temporary differences reported in the Changes in deferred tax position by nature summary include Allowance for Corporate Equity in Italy
of €1,267 million (gross) in 2024 (€1,298 million (gross) in 2023) and Advanced Corporate Tax in the United Kingdom of €27 million in 2024 (€26 million in 2023)
At January 1,
2023
Recognized in
Consolidated
Income
Statement
Recognized in
Equity
Transferred
to Assets/
(Liabilities)
Held for Sale
Translation
differences
and Other
At December
31, 2023
(€ million)
Deferred tax liabilities arising on:
Accelerated depreciation
€(2,775)
€(315)
€—
€—
€(12)
€(3,102)
Capitalized development assets
(4,296)
332
—
—
43
(3,921)
Other Intangible assets and
Intangible assets with indefinite
useful lives
(3,964)
(12)
—
—
107
(3,869)
Right-of-use assets
(331)
29
—
—
26
(276)
Provision for employee benefits
(1,086)
(4)
(23)
—
35
(1,078)
Other
(1,488)
48
235
(26)
186
(1,045)
Total deferred tax liabilities
€(13,941)
€78
€212
€(26)
€385
€(13,291)
Deferred tax assets arising on:
Provisions
4,852
(304)
(37)
—
(43)
4,468
Provision for employee benefits
2,183
(208)
6
—
(28)
1,953
Lease liabilities
373
(8)
2
—
(31)
336
Impairment of tangible and
intangible assets
1,269
(376)
(1)
—
(15)
877
Inventories
375
62
5
—
2
444
Allowances for doubtful
accounts
58
10
(1)
—
(8)
59
Provision for buy back
169
1
—
—
(17)
153
Other
2,589
(156)
172
—
377
2,982
Total deferred tax assets
€11,868
€(979)
€146
€—
€237
€11,272
Unrecognized deferred tax assets
on temporary differences(1)
(3,183)
311
11
—
(516)
(3,377)
Deferred tax assets arising on tax
loss carry-forwards
9,506
(402)
—
—
(35)
9,069
Unrecognized deferred tax assets
on tax loss carry-forwards
(6,531)
260
—
—
(34)
(6,305)
Total Net deferred tax assets /
(liabilities)
€(2,280)
€(732)
€369
€(26)
€37
€(2,632)
________________________________________________________________________________________________________________________________________________
(1) Unrecognized deferred tax assets on temporary differences reported in the Changes in deferred tax position by nature summary include Allowance for Corporate Equity in Italy
of €1,298 million (gross) in 2023 (€1,215 million (gross) in 2022) and Advanced Corporate Tax in the United Kingdom of €26 million in 2023 (€26 million in 2022)
In accordance with IAS 12 - Income Taxes, deferred taxes are calculated for all temporary differences between the
tax base of assets and liabilities and their carrying amount. Deferred tax liabilities are systematically recognized, while
deferred tax assets are recognized for all deductible temporary differences to the extent that it is probable that taxable profit is
available against which the deductible temporary differences could be utilized. A deferred tax liability is recognized for all
taxable temporary differences associated with investments in subsidiaries and equity method investments for the variance
between their tax and accounting value, except to the extent that both of the following conditions are satisfied: (i) Stellantis is
able to control the timing of the reversal of the temporary difference; (ii) it is probable that the temporary difference will not
reverse in the foreseeable future.
At December 31, 2024, the aggregate amount of temporary differences relating to investments in subsidiaries and
interests in joint ventures for which deferred tax liabilities are not recognized is approximately €530 million. (€379 million at
December 21, 2023).
As of December 31, 2024, the Company had total Deferred tax assets on deductible temporary differences of
€11,381 million (€11,272 million at December 31, 2023), of which €2,657 million was not recognized (€3,377 million at
December 31, 2023). As of December 31, 2024, the Company also had Deferred tax assets on tax loss carry-forwards of
€8,782 million (€9,069 million at December 31, 2023), of which €4,094 million was not recognized (€6,305 million at
December 31, 2023).
Tax loss carry-forwards
Recognition of deferred tax assets related to tax loss carry-forwards were tested for realizability based on forecasted
future taxable income using estimates consistent with the main assumptions of the MTP. Deferred tax assets relating to the
carry-forward of unused tax losses and tax credits, as well as those arising from deductible temporary differences, were
recognized to the extent that it was probable that future profits would be available against which they could be utilized. The
realization of these deferred tax assets was sensitive to the assumptions and judgments used in the determination of the
taxable income in the future, as well as Stellantis’ ability to implement tax planning strategies, as necessary. While Stellantis
has not recognized all deferred tax assets in all jurisdictions, it is possible the Company’s assessment of realizability could
change, resulting in the recognition of additional deferred tax assets in the Company’s Consolidated Statement of Financial
Position and the related income tax benefit in the Company’s Consolidated Income Statement. Refer to Note 2, Basis of
preparation - Critical judgements and use of estimates - Recoverability of deferred tax assets for additional information.
Tax loss carry-forward
(after application of the
current tax rate)
Recognized deferred tax
assets on tax loss carry-
forward
Unrecognized deferred tax
assets on tax loss carry-
forwards (after application
of the current tax rate)
At December 31, 2024
(€ million)
Tax Groups:
France
€1,640
€(1,621)
€19
Germany
381
(381)
—
Spain
509
(95)
414
Italy
3,665
(639)
3,026
Other Jurisdictions:
Brazil
1,921
(1,616)
305
Others
666
(337)
329
Total
€8,782
€(4,689)
€4,093
Tax loss carry-forward
(after application of the
current tax rate)
Recognized deferred tax
assets on tax loss carry-
forward
Unrecognized deferred tax
assets on tax loss carry-
forwards (after application
of the current tax rate)
At December 31, 2023
(€ million)
Tax Groups:
France
€1,663
€(1,645)
€18
Germany
120
(120)
—
Spain
561
(63)
498
Italy
3,499
(605)
2,894
Other Jurisdictions:
Brazil
2,411
—
2,411
Others
815
(331)
484
Total
€9,069
€(2,764)
€6,305
At December 31 2024 and 2023, the Company had total tax-effected tax loss carry-forwards of €8.8 billion and
€9.1 billion, respectively, of which €4.1 billion and €6.3 billion were not recognized, respectively. The majority of the
Company’s tax loss carry-forwards do not expire, such as France, Germany, Italy, Spain and Brazil. Tax loss carry-forwards
relating to the French, German, Spanish and Italian tax groups are available within each tax group for offsetting against net
deferred tax liabilities (subject to limitations provided under local tax law) and are recognized in the Consolidated Statement
of Financial Position.
Pillar Two
The OECD Pillar Two agreement aims to ensure that multinational corporations pay a minimum effective tax rate of
15 percent on a jurisdictional basis. In December 2023, the Netherlands enacted Pillar Two legislation that is effective from
January 1, 2024. As the Netherlands is the jurisdiction of Stellantis N.V., the Company’s ultimate parent, the Dutch Pillar
Two rules are effective for the Company’s financial year beginning January 1, 2024. Other jurisdictions in which we operate
have enacted local Pillar Two legislation effective from January 1, 2024.
The Company has reviewed its corporate structure in light of the enactment of the Pillar Two global minimum tax
rules in the Netherlands and other jurisdictions in which we operate. Our assessment includes analyzing whether jurisdictions
in which we operate have a Pillar Two effective tax rate below 15 percent and analyzing jurisdictions where we receive tax
incentives to assess whether these rules may result in an offset of all or a portion of the tax incentives in the form of a Pillar
Two tax.
For 2024, our assessment of the potential exposure to Pillar Two income taxes is based on the country-by-country
reporting for 2023 and the latest financial information for 2024 for the constituent entities of the Company. Based on this
assessment, our expected exposure to Pillar Two income taxes does not have a material impact on tax expense and relates to
our profits earned in the United Arab Emirates where the Pillar Two transitional safe harbor does not apply and the Pillar
Two effective rate is below 15 percent.