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Income taxes
12 Months Ended
Dec. 31, 2023
Income Taxes [Line Items]  
Disclosure Of Income Tax Explanatory
Note 9
 
Income taxes
 
 
 
 
 
 
 
 
 
 
 
 
For the year ended
USD m
31.12.23
31.12.22
31.12.21
Tax expense / (benefit)
Swiss
Current
883
730
680
Deferred
152
(15)
34
Total Swiss
1,035
715
714
Non-Swiss
Current
684
718
884
Deferred
(846)
509
400
Total non-Swiss
(162)
1,227
1,284
Total income tax expense / (benefit) recognized in the income statement
873
1,942
1,998
Income tax recognized in the income statement
The Swiss current tax expenses related to taxable profits
 
of UBS Switzerland AG and other Swiss entities.
The Swiss deferred tax expenses primarily related to the amortization of deferred tax assets (DTAs), as deductions related
to temporary differences were made against profits.
The non-Swiss
 
current tax
 
expenses related
 
to expenses
 
of USD
100
m in
 
respect of
 
US corporate
 
alternative minimum
tax (CAMT) and USD
584
m in respect of other taxable profits of non-Swiss subsidiaries
 
and branches.
The non-Swiss net deferred tax
 
benefit primarily related to a
 
benefit of USD
754
m in respect of
 
remeasurements of DTAs,
which
 
included
 
USD
480
m
 
in
 
respect
 
of
 
net
 
upward
 
revaluations
 
of
 
DTAs
 
for
 
certain
 
entities
 
in
 
connection
 
with
 
the
Group’s business planning process and USD
274
m in respect of an increase in DTAs that resulted from an increase in the
expected value of future tax deductions for deferred compensation awards due to an increase in the Group’s share price
during the year.
 
In addition, the
 
net deferred tax
 
benefit also included
 
a benefit of
 
USD
100
m in respect
 
of the recognition
of DTAs
 
for
 
tax
 
credits carried
 
forward
 
in respect
 
of CAMT,
 
which
 
was
 
partly
 
offset
 
by a
 
net
 
deferred
 
tax expense
 
of
USD
8
m.
The low effective
 
tax rate for
 
the year of
3.0
% primarily reflected
 
that the negative
 
goodwill gain that
 
was recorded in
the income statement
 
did not result
 
in any tax
 
expense, as well
 
as the aforementioned tax
 
benefit of USD
754
m in respect
of the remeasurement
 
of DTAs. However,
 
these benefits
 
were partly offset
 
by the impact
 
of operating losses
 
that were
incurred by certain entities,
 
reflecting integration-related
 
expenses and restructuring costs,
 
that did not result
 
in any tax
benefits because they cannot
 
be offset with profits
 
of other group entities and
 
they did not result in
 
any DTA recognition.
If further
 
such operating
 
losses are
 
incurred in
 
2024, the
 
Group’s tax
 
expense for
 
the year
 
may be
 
significantly higher
than the Group’s structural rate of
23
%, but the Group’s effective tax rate
 
is expected to decrease towards the structural
rate in subsequent years, as such losses decrease.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
For the year ended
USD m
31.12.23
31.12.22
31.12.21
Operating profit / (loss) before tax
28,739
9,604
9,484
of which: Swiss
32,300
4,425
3,334
of which: non-Swiss
(3,561)
5,178
6,150
Income taxes at Swiss tax rate of
18.5
% for 2023,
18
% for 2022 and
18.5
% for 2021
5,317
1,729
1,755
Increase / (decrease) resulting from:
Non-Swiss tax rates differing from Swiss tax rate
(224)
284
234
Tax effects of losses not recognized
1,584
74
124
Previously unrecognized tax losses now utilized
(401)
(217)
(179)
Non-taxable and lower-taxed income
1
(5,730)
(335)
(278)
Non-deductible expenses and additional taxable income
1,651
429
510
Adjustments related to prior years, current tax
(87)
(41)
(40)
Adjustments related to prior years, deferred tax
(1)
13
(10)
Change in deferred tax recognition
(1,288)
(217)
(342)
Adjustments to deferred tax balances arising from changes
 
in tax rates
26
0
(5)
Other items
25
222
231
Income tax expense / (benefit)
873
1,942
1,998
1 The reconciling item for non-taxable and lower-taxed
 
income for 2023 primarily reflects that the negative goodwill gain that
 
was recorded in the income statement in relation to
 
the acquisition of Credit Suisse did
not result in any tax expense.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The components of
 
operating profit before tax,
 
and the differences between
 
income tax expense
 
reflected in the
 
financial
statements and the amounts calculated at the Swiss tax rate,
 
are provided in the table above and explained
 
below.
Component
Description
Non-Swiss tax rates
differing from the
Swiss tax rate
To the extent that Group profits or losses arise outside Switzerland, the applicable local tax
 
rate may differ from the Swiss
tax rate. This item reflects, for such profits, an adjustment
 
from the tax expense that would arise at the
 
Swiss tax rate to
the tax expense that would arise at the applicable
 
local tax rate. Similarly, it reflects, for such losses, an adjustment from
the tax benefit that would arise at the Swiss tax
 
rate to the tax benefit that would arise
 
at the applicable local tax rate.
Tax effects of losses
not recognized
This item relates to tax losses of entities arising in the
 
year that are not recognized as DTAs and where no tax benefit arises
in relation to those losses. Therefore, the tax benefit calculated
 
by applying the local tax rate to those losses
 
as described
above is reversed.
Previously
unrecognized tax losses
now utilized
This item relates to taxable profits of the year that are offset by tax losses
 
of previous years for which no DTAs were
previously recorded. Consequently, no current tax or deferred tax expense arises in relation to those taxable
 
profits and
the tax expense calculated by applying the local
 
tax rate on those profits is reversed.
Non-taxable and lower-
taxed income
This item relates to tax deductions for the year in
 
respect of permanent differences. These include deductions in
 
respect of
profits that are either not taxable or are taxable at a lower rate
 
of tax than the local tax rate. They also
 
include deductions
made for tax purposes, which are not reflected in the
 
accounts.
Non-deductible
expenses and
additional taxable
income
This item relates to additional taxable income for
 
the year in respect of permanent differences. These include
 
income that
is recognized for tax purposes by an entity but is
 
not included in its profit that is reported in the financial
 
statements, as
well as expenses for the year that are non-deductible
 
(e.g., client entertainment costs are not deductible
 
in certain
locations).
Adjustments related to
prior years,
 
current tax
This item relates to adjustments to current tax expense for
 
prior years (e.g., if the tax payable for a year is
 
agreed with the
tax authorities in an amount that differs from the amount
 
previously reflected in the financial statements).
Adjustments related to
prior years,
 
deferred
tax
This item relates to adjustments to deferred tax positions
 
recognized in prior years (e.g., if a tax loss
 
for a year is fully
recognized and the amount of the tax loss agreed with
 
the tax authorities is expected to differ from the
 
amount previously
recognized as DTAs in the accounts).
Change in deferred tax
recognition
This item relates to changes in DTAs, including changes in DTAs previously recognized resulting from reassessments of
expected future taxable profits. It also includes changes
 
in temporary differences in the year, for which deferred tax is not
recognized.
Adjustments to
deferred tax balances
arising from changes in
tax rates
This item relates to remeasurements of DTAs and liabilities recognized due to changes
 
in tax rates. These have the effect
of changing the future tax saving that is expected from tax
 
losses or deductible tax differences and therefore the amount
of DTAs recognized or, alternatively,
 
changing the tax cost of additional taxable
 
income from taxable temporary
differences and therefore the deferred tax liability.
Other items
Other items include other differences between profits or losses
 
at the local tax rate and the actual local tax
 
expense or
benefit, including movements in provisions for uncertain
 
positions in relation to the current year and other items.
Income tax recognized directly in equity
A net tax expense of USD
314
m was recognized in
Other comprehensive income
 
(2022: net benefit of USD
1,116
m) and
a net tax benefit of USD
19
m was recognized in
Share premium
(2022: net benefit of USD
13
m).
Deferred tax assets and liabilities
The Group has gross
 
DTAs, valuation
 
allowances and recognized
 
DTAs related
 
to tax loss carry-forwards
 
and deductible
temporary differences, as well as deferred tax liabilities in respect of taxable temporary differences, as shown in
 
the table
below.
 
The valuation
 
allowances reflect
 
DTAs
 
that were
 
not recognized
 
because, as
 
of the
 
last remeasurement
 
period,
management
 
did not
 
consider
 
it probable
 
that
 
there
 
would be
 
sufficient
 
future
 
taxable
 
profits
 
available
 
to utilize
 
the
related tax loss carry-forwards and deductible
 
temporary differences.
The recognition of DTAs is
 
supported by forecasts of taxable
 
profits for the entities concerned.
 
In addition, tax planning
opportunities are available that would
 
result in additional future taxable
 
income and these would be
 
utilized, if necessary.
Deferred tax
 
liabilities are recognized
 
in respect of
 
investments in subsidiaries,
 
branches and associates,
 
and interests in
joint arrangements, except
 
to the extent that
 
the Group can control the
 
timing of the reversal
 
of the associated taxable
temporary difference and it is probable that such will not reverse in the foreseeable
 
future. However, as of 31 December
2023, this exception was not considered to apply to any
 
taxable temporary differences.
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
USD m
31.12.23
31.12.22
Deferred tax assets
1
Gross
Valuation
allowance
Recognized
Gross
Valuation
allowance
Recognized
Tax loss carry-forwards
19,070
(16,078)
2,992
12,708
(8,720)
3,988
Unused tax credits
95
0
95
0
0
0
Temporary differences
11,159
(3,564)
7,595
5,814
(414)
5,400
of which: related to real estate costs capitalized for US
 
tax
purposes
2,703
0
2,703
2,485
0
2,485
of which: related to compensation and benefits
1,795
(471)
1,324
1,194
(175)
1,018
of which: related to cash flow hedges
765
(139)
626
947
0
947
of which: other
5,896
(2,954)
2,942
1,188
(238)
950
Total deferred tax assets
30,324
(19,642)
10,682
2
18,522
(9,134)
9,389
2
of which: related to the US
9,023
8,294
of which: related to other locations
1,659
1,095
Deferred tax liabilities
Total deferred tax liabilities
325
236
1 After offset of DTLs, as applicable.
 
2 As of 31 December 2023, the Group recognized DTAs of USD
426
m (31 December 2022: USD
471
m) in respect of entities that incurred losses in either
 
the current or preceding
year.
In general, US federal tax losses incurred prior
 
to 31 December 2017 can be carried
 
forward for 20 years. US federal tax
losses incurred after that date
 
can be carried forward indefinitely,
 
although the utilization of such
 
losses is limited to
 
80%
of the
 
entity’s future
 
year taxable
 
profits. UK
 
tax losses
 
can also
 
be carried
 
forward indefinitely;
 
they can
 
shelter up
 
to
either 25% or 50%
 
of future year taxable
 
profits, depending on when
 
the tax losses
 
arose. The amounts of
 
US tax loss
carry-forwards that
 
are included
 
in the table
 
below are
 
based on their
 
amount for
 
federal tax
 
purposes rather
 
than for
state and local tax purposes.
 
 
 
 
 
 
 
 
 
 
 
Unrecognized tax loss carry-forwards
USD m
31.12.23
31.12.22
Within 1 year
342
231
From 2 to 5 years
10,839
2,184
From 6 to 10 years
7,114
11,106
From 11 to 20 years
1,818
1,610
No expiry
44,222
16,960
Total
64,335
32,091
of which: related to the US
1
12,354
13,350
of which: related to the UK
37,773
14,332
of which: related to other locations
14,208
4,409
1 Related to UBS AG’s US branch.