v3.24.4
Income Tax
12 Months Ended
Sep. 30, 2024
Disclosure of income tax [abstract]  
Income Tax
17.
INCOME TAX

The major components of income tax expense are as follows:

 

 

 

Year ended September 30,

 

 

 

2024

 

 

2023

 

 

2022

 

Current income taxes

 

 

(78,366

)

 

 

(50,849

)

 

 

(66,336

)

Deferred income taxes

 

 

(23,814

)

 

 

(27,781

)

 

 

2,923

 

Income tax expense

 

 

(102,180

)

 

 

(78,630

)

 

 

(63,413

)

 

For the periods ended September 30, 2024 and 2023, the UK corporate income tax rate of 25% was used to calculate the current taxes due to the migration of Birkenstock Holding plc from Luxembourg to Jersey. The Company has its registered seat in Jersey whereas the effective place of management is in the UK which gives rise to the Company being subject to

UK corporate income tax resulting in an application of the UK corporate income tax rate of 25% instead of the Jersey corporate income tax rate of 0%.

For the period ended September 30, 2022, the Company applied the the Luxembourg corporate income tax rate of 22.8%.

For the foreign subsidiaries, country-specific tax rates were used for each respective period. The calculation of deferred tax assets and deferred tax liabilities was based on tax rates that are likely to be applicable in the period of reversal of the deferred tax assets and deferred tax liabilities.

The income taxes calculated at the effective tax rate reconcile as follows:

 

 

 

Year ended September 30,

 

 

 

2024

 

 

2023

 

 

2022

 

Net profit before tax

 

 

293,782

 

 

 

153,652

 

 

 

250,524

 

Expected income tax expense at a 25% statutory UK tax rate (prior period: 25% / 22.8% statutory UK and Luxemburg tax rate)

 

 

(73,446

)

 

 

(38,413

)

 

 

(57,120

)

Increased/ decreased by:

 

 

 

 

 

 

 

 

 

- Non-deductible expenses for tax purposes

 

 

(2,175

)

 

 

(2,699

)

 

 

(1,812

)

- Non-deductible share-based compensation

 

 

(1,098

)

 

 

(19,880

)

 

 

—

 

- Change in permanent items

 

 

—

 

 

 

687

 

 

 

—

 

- Minimum Taxation

 

 

(1,915

)

 

 

—

 

 

 

—

 

- Income exempted from tax

 

 

1,247

 

 

 

—

 

 

 

—

 

- Previous years taxes

 

 

(5,396

)

 

 

(5,461

)

 

 

—

 

- Changes in non-recognition of deferred tax assets on temporary differences/tax loss carry forwards

 

 

(11,369

)

 

 

(8,400

)

 

 

(783

)

- Tax rate differences

 

 

(13,410

)

 

 

(5,628

)

 

 

(14,202

)

- Tax rate changes

 

 

2,461

 

 

 

(142

)

 

 

—

 

- Other

 

 

2,921

 

 

 

1,306

 

 

 

10,504

 

Effective income tax expense

 

 

(102,180

)

 

 

(78,630

)

 

 

(63,413

)

The net deferred tax assets and liabilities mainly relate to the following differences between IFRS and the tax base and are shown in the following table:

 

 

 

September 30, 2024

 

 

September 30, 2023

 

 

 

Assets

 

 

Liabilities

 

 

Assets

 

 

Liabilities

 

Trade receivables

 

 

45

 

 

 

149

 

 

 

223

 

 

 

—

 

Inventories

 

 

64,093

 

 

 

4,385

 

 

 

59,714

 

 

 

2,602

 

Other current assets

 

 

79

 

 

 

2,413

 

 

 

30

 

 

 

125

 

Property, plant and equipment

 

 

6,712

 

 

 

9,580

 

 

 

1,240

 

 

 

9,005

 

Right-of-use assets

 

 

—

 

 

 

45,681

 

 

 

—

 

 

 

27,037

 

Intangible assets

 

 

—

 

 

 

204,456

 

 

 

—

 

 

 

168,297

 

Other current financial liabilities

 

 

12,025

 

 

 

—

 

 

 

7,571

 

 

 

—

 

Other current liabilities

 

 

2,450

 

 

 

926

 

 

 

674

 

 

 

737

 

Current provisions

 

 

10,103

 

 

 

3,012

 

 

 

8,815

 

 

 

627

 

Other non-current financial liabilities

 

 

37,713

 

 

 

7,363

 

 

 

22,245

 

 

 

17,433

 

Tax loss and interest carryforwards

 

 

13,861

 

 

 

—

 

 

 

15,559

 

 

 

—

 

Deferred tax assets (liabilities)

 

 

147,080

 

 

 

277,966

 

 

 

116,069

 

 

 

225,863

 

Offsetting

 

 

(146,963

)

 

 

(146,963

)

 

 

(116,069

)

 

 

(116,069

)

Deferred tax assets (liabilities) on balance sheet

 

 

117

 

 

 

131,003

 

 

 

—

 

 

 

109,794

 

 

The deferred taxes developed as follows:

 

 

 

September 30, 2024

 

 

September 30, 2023

 

Net amount at October 1

 

 

(109,794

)

 

 

(88,261

)

thereof deferred tax assets

 

 

—

 

 

 

4,590

 

thereof deferred tax liabilities

 

 

(109,794

)

 

 

(92,851

)

Taxes charged:

 

 

 

 

 

 

to income statement

 

 

(23,814

)

 

 

(27,781

)

to other comprehensive income

 

 

 

 

 

 

Exchange differences

 

 

2,722

 

 

 

6,249

 

Net amount at September 30

 

 

(130,886

)

 

 

(109,794

)

thereof deferred tax assets

 

 

117

 

 

 

—

 

thereof deferred tax liabilities

 

 

(131,003

)

 

 

(109,794

)

 

For the following (gross) items, no deferred taxes were recognized:

 

 

 

September 30, 2024

 

 

September 30, 2023

 

Tax loss carry forwards

 

 

99,851

 

 

 

53,050

 

 

 

99,851

 

 

 

53,050

 

 

Tax loss carry forwards mainly relate to the Company and foreign entities, which can be carried forward indefinitely. However, due to insufficient projected future taxable income, no deferred taxes on the aforementioned tax loss carry forwards were recognized for the respective periods.

The Company did not recognize deferred tax liabilities for income taxes or foreign withholding taxes on the cumulative earnings of subsidiaries of €597.5 million as of September 30, 2024 (September 30, 2023: €580.5 million) as these are intended to be reinvested.

In December 2021, the OECD published key parameters and model rules on a global minimum tax of 15% (Pillar Two) for multinational enterprises with revenue of more than €750.0 million. Some of the jurisdictions in which we are subject to income taxes, global minimum tax rules have been enacted which can impose detailed reporting obligations and increase compliance and systems-related costs on our businesses. In the UK, where the Company is headquartered, such rules were enacted in July 2023. The Company is not yet subject to these rules as they are effective for fiscal years beginning on or after January 1, 2024. We are continuing to assess the impact of the Pillar Two rules on our business. Currently, we do not expect significant additional tax burden from fiscal year 2025 onwards.