Income Tax (Tables)
|
12 Months Ended |
Dec. 31, 2023 |
Sep. 30, 2023 |
| Income Tax Disclosure [Line Items] |
|
|
| Changes in our unrecognized tax benefits |
The changes in our unrecognized tax benefits for the indicated periods are summarized below:
|
|
|
|
|
|
|
|
|
|
|
2023 |
|
|
2022 |
|
|
|
(as restated) |
|
|
(as restated) |
|
Balance at January 1 |
|
$ |
24,388,433 |
|
|
$ |
11,811,695 |
|
Effect of rate changes |
|
|
— |
|
|
|
— |
|
Additions based on tax positions related to current year |
|
|
6,882,336 |
|
|
|
13,857,760 |
|
Foreign currency translation |
|
|
2,483,300 |
|
|
|
(1,281,022 |
) |
Balance at December 31 |
|
|
33,754,069 |
|
|
|
24,388,433 |
|
|
|
| The Company and its subsidiaries are liable to income taxes in their respective jurisdiction |
The Company and its subsidiaries are liable to income taxes in their respective jurisdiction. The Company has unused tax losses as follows as at December 31, 2023:
|
|
|
|
|
|
|
|
|
Subsidiaries in Jurisdiction |
|
Tax loss carryforward |
|
|
Expiration date |
|
UK (1) |
|
|
191,771,010 |
|
|
|
(1 |
) |
US |
|
|
5,542,459 |
|
|
Indefinite |
|
Spain |
|
|
844,411 |
|
|
Indefinite |
|
India |
|
|
— |
|
|
N/A |
|
Taiwan |
|
|
2,359,658 |
|
|
10 years |
|
|
|
| Current Income Tax Expense (Benefit) |
Current Income tax expense (benefit) consists of:
|
|
|
|
|
|
|
|
|
|
|
December 31, 2023 |
|
|
December 31, 2022 |
|
|
|
(as restated) |
|
|
(as restated) |
|
Taiwan |
|
|
— |
|
|
|
10,639 |
|
India |
|
|
63,408 |
|
|
|
28,126 |
|
Total |
|
|
63,408 |
|
|
|
38,765 |
|
|
|
| Components of loss (income) before income taxes |
The components of our loss (income) before income taxes are as follows:
|
|
|
|
|
|
|
|
|
|
|
December 31, 2023 |
|
|
December 31, 2022 |
|
|
|
(as restated) |
|
|
(as restated) |
|
UK |
|
$ |
29,427,631 |
|
|
$ |
107,945,740 |
|
US |
|
|
994,933 |
|
|
|
634,526 |
|
Spain |
|
|
298,927 |
|
|
|
381,321 |
|
India |
|
|
(92,982 |
) |
|
|
(300,433 |
) |
Taiwan |
|
|
44,181 |
|
|
|
2,051,794 |
|
Total |
|
|
30,672,980 |
|
|
|
110,712,948 |
|
|
|
| Significant portions of our deferred tax assets and liabilities |
The tax effects of temporary differences that give rise to the significant portions of our deferred tax assets and liabilities are presented below:
|
|
|
|
|
|
|
|
|
|
|
December 31, 2023 |
|
|
December 31, 2022 |
|
|
|
(as restated) |
|
|
(as restated) |
|
Deferred tax assets: |
|
|
|
|
|
|
Net operating loss and other carryforwards |
|
$ |
33,754,069 |
|
|
$ |
24,388,433 |
|
PP&E |
|
|
— |
|
|
|
2,661 |
|
Short-term debt |
|
|
1,556,454 |
|
|
|
174,267 |
|
Share-based payment liability |
|
|
327,757 |
|
|
|
294,404 |
|
Convertible debt |
|
|
8,110,222 |
|
|
|
6,325,677 |
|
Deferred tax assets |
|
|
43,748,501 |
|
|
|
31,185,442 |
|
Valuation allowance |
|
|
(43,748,501 |
) |
|
|
(31,185,442 |
) |
Deferred tax assets, net of valuation allowance |
|
|
— |
|
|
|
— |
|
|
|
| Reconciliation of the federal income tax rate to the company's effective tax rate |
Income tax benefit attributable to our loss before income taxes differs from the amounts computed using the applicable income tax rate as a result of the following factors:
|
|
|
|
|
|
|
|
|
|
|
December 31, 2023 |
|
|
December 31, 2022 |
|
|
|
(as restated) |
|
|
(as restated) |
|
Loss before income taxes |
|
$ |
(30,672,690 |
) |
|
$ |
(110,712,948 |
) |
Income tax benefit at statutory tax rates (a) |
|
|
7,208,082 |
|
|
|
21,035,460 |
|
Effect of: |
|
|
|
|
|
|
Non-deductible or non-taxable foreign currency exchange
results |
|
|
(88,195 |
) |
|
|
(214,299 |
) |
International rate differences (b) |
|
|
(9,845 |
) |
|
|
282,884 |
|
Non-deductible expenses |
|
|
(2,050,426 |
) |
|
|
(14,818,455 |
) |
Change in valuation allowance |
|
|
(4,996,208 |
) |
|
|
(6,246,825 |
) |
Income tax expense |
|
|
63,408 |
|
|
|
38,765 |
|
(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. (b)Amounts reflect adjustments (either a benefit or expense) to the “expected” tax expense for statutory rates in jurisdictions in which we operate outside of the UK.
|
|
| Armada Acquisition Corp I [Member] |
|
|
| Income Tax Disclosure [Line Items] |
|
|
| Significant portions of our deferred tax assets and liabilities |
|
The Company’s net deferred tax assets are as follows:
|
|
|
|
|
|
|
|
|
|
|
September 30, |
|
|
|
2023 |
|
|
2022 |
|
Deferred tax asset |
|
|
|
|
|
|
Organizational costs/Startup expenses |
|
$ |
504,667 |
|
|
$ |
351,592 |
|
Stock-based compensation |
|
|
129,350 |
|
|
|
83,517 |
|
Total deferred tax asset |
|
|
634,017 |
|
|
|
435,209 |
|
Valuation allowance |
|
|
(634,017 |
) |
|
|
(435,209 |
) |
Deferred tax asset, net of allowance |
|
$ |
— |
|
|
$ |
— |
|
|
| The income tax provision |
|
The income tax provision consists of the following:
|
|
|
|
|
|
|
|
|
|
|
September 30, |
|
|
|
2023 |
|
|
2022 |
|
Federal |
|
|
|
|
|
|
Current |
|
$ |
615,284 |
|
|
$ |
145,621 |
|
Deferred |
|
|
(198,808 |
) |
|
|
(336,741 |
) |
State |
|
|
|
|
|
|
Current |
|
|
— |
|
|
|
— |
|
Deferred |
|
|
— |
|
|
|
— |
|
Change in valuation allowance |
|
|
198,808 |
|
|
|
336,741 |
|
Income tax provision |
|
$ |
615,284 |
|
|
$ |
145,621 |
|
|
| Reconciliation of the federal income tax rate to the company's effective tax rate |
|
A reconciliation of the federal income tax rate to the Company’s effective tax rate at September 30, 2023 and 2022 are as follows:
|
|
|
|
|
|
|
|
|
|
|
September 30, |
|
|
|
2023 |
|
|
2022 |
|
Statutory federal income tax rate |
|
|
21.00 |
% |
|
|
21.00 |
% |
State taxes, net of federal tax benefit |
|
|
0.00 |
% |
|
|
0.00 |
% |
Prior year true up |
|
|
0.99 |
% |
|
|
— |
|
Business combination expenses |
|
|
119.13 |
% |
|
|
(15.50 |
)% |
Change in valuation allowance |
|
|
67.40 |
% |
|
|
(9.70 |
)% |
Income tax provision |
|
|
207.49 |
% |
|
|
(4.25 |
)% |
|