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INCOME TAXES (Tables)

12 Months Ended

Dec. 31, 2025

Schedule of Components of Loss From Continuing Before Income Taxes

The following table sets forth the components of loss from continuing operations before income taxes by jurisdiction:


	Year Ended December 31,
(in millions)	2025		2024		2023
Ireland (2025), Netherlands (2024-2023)	$	0.3	$	(258.7)	$	(199.3)
Non-Ireland (2025), Non-Netherlands (2024-2023)	(210.1)		(431.8)		(313.5)
Loss from continuing operations before income taxes	$	(209.8)	$	(690.5)	$	(512.8)

Schedule of Components of Income Tax Expense From Continuing Operations

The following table sets forth the components of income tax expense from continuing operations:


	Year Ended December 31,
(in millions)	2025		2024		2023
Current taxes:
Ireland (2025), Netherlands (2024-2023)	$	0.4	$	2.7	$	0.9
Non-Ireland (2025), Non-Netherlands (2024-2023)	141.2		146.6		89.6
Total	141.6		149.3		90.5
Deferred taxes:
Ireland (2025), Netherlands (2024-2023)	—		(0.1)		(5.2)
Non-Ireland (2025), Non-Netherlands (2024-2023)	(6.1)		(35.5)		(33.5)
Total	(6.1)		(35.6)		(38.7)
Income tax expense from continuing operations	$	135.5	$	113.7	$	51.8

Schedule of Effective Income Tax Rate Reconciliation

The Company’s income tax expense from continuing operations was different from the amount computed by applying the Ireland (2025) and the Netherlands (2024-2023) statutory tax rate to the underlying loss from continuing operations before income taxes as a result of the following:


	Year Ended December 31, 2025
(in millions)	$		%
Income taxes at Ireland statutory tax rate	$	(26.2)	12.5	%
Ireland reconciling items
Valuation allowance	0.5		(0.2)	%
Other	(0.2)		0.1	%
Foreign reconciling items
Brazil
Withholding tax	9.1		(4.3)	%
Other	0.8		(0.4)	%
Germany

Changes in valuation allowance	(42.5)		20.3	%

Interest carryforward	54.4		(25.9)	%
Other	(2.6)		1.2	%



Netherlands


Warrant	10.3		(4.9)	%
Other	(5.0)		2.4	%



Switzerland
Changes in valuation allowance	11.9		(5.7)	%
Other	(1.3)		0.6	%
United States
Tax rate differential	(17.9)		8.5	%
Nontaxable and nondeductible items, net	11.7		(5.6)	%
Changes in valuation allowance	24.5		(11.7)	%
Stock compensation	8.3		(4.0)	%
Other	3.6		(1.7)	%

Mexico	10.2		(4.9)	%
India	10.7		(5.1)	%
Other jurisdictions	61.5		(29.3)	%
Changes in unrecognized tax benefits	13.7		(6.5)	%
Global effective tax rate	$	135.5	(64.6)	%


	Year Ended December 31,
(in millions)	2024			2023
Loss from continuing operations before income taxes	$	(690.5)		$	(512.8)
Netherlands statutory tax rate	25.8		%	25.8		%
Benefit for income taxes at the Netherlands statutory rate	$	(178.1)		$	(132.6)
Foreign tax rate differential	24.4			20.2
U.S. state and local taxation	0.5			0.9
Changes in valuation allowance	180.7			92.4
Withholding taxes	32.5			38.4
Non-deductible transaction costs	4.1			6.8
Gain on equity interest remeasurement	—			(3.4)
Russian deconsolidation	9.0			—
Change in unrecognized tax benefits	30.7			(4.8)
Return to provision adjustment	(1.2)			4.8
Tax credits	(5.2)			(3.3)
Warrant	19.4			26.1
Other, net	(3.1)			6.3
Income tax expense from continuing operations	$	113.7		$	51.8
Effective tax rate	(16.5)		%	(10.1)		%

Schedule of Deferred Tax Assets and Liabilities

The following table sets forth deferred income tax assets and liabilities:


	December 31,
(in millions)	2025		2024
Deferred tax assets:
Net operating loss carryforwards	$	326.2	$	285.6
Interest	183.4		236.7
Accrued expenses	39.7		42.0
Employee benefits	33.3		42.9
Tax credit carryforward	17.7		13.9

Lease liabilities	64.8		64.5
Other assets	48.7		37.6
Total deferred tax asset	713.8		723.2
Valuation allowances	(527.8)		(530.8)
Deferred tax assets, net of valuation allowances	186.0		192.4
Deferred tax liabilities:
Intangible assets	(161.4)		(161.7)

Right-of-use assets	(64.6)		(59.1)
Accrued withholding taxes	(15.0)		(13.5)
Deferred gains	(34.4)		(42.8)
Other	(6.2)		(2.2)
Total deferred tax liability	(281.6)		(279.3)
Net deferred tax liability	$	(95.6)	$	(86.9)

Schedule of Unrecognized Tax Benefits Roll Forward

A reconciliation of the beginning and ending amount of gross uncertain tax positions is as follows:


	Year Ended December 31,
(in millions)	2025		2024
Balance as of the beginning of period	$	69.0	$	64.4

Additions for current year positions	4.1		4.1
Additions for prior year positions	7.0		24.6
Reductions for prior year positions	(0.6)		(9.1)
Reductions for expiration of statute of limitations	(0.1)		—
Settlements	(12.1)		(11.6)
Foreign currency exchange rate changes	5.7		(3.4)
Balance as of the end of the period	$	73.0	$	69.0

Schedule of Total Tax Payments By Jurisdiction

The following table sets forth total tax payments by jurisdiction:


	Year Ended December 31,
(in millions)	2025
Ireland	$	0.4
Brazil	18.0
China	5.8
Colombia	5.2
France	4.5
India	10.9
Indonesia	12.5
Italy	4.1
Mexico	6.7
Other jurisdictions	63.4
Total tax payments	$	131.5