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INCOME TAXES
 12 Months Ended
Dec. 31, 2024
Income Tax Disclosure [Abstract]  
INCOME TAXES INCOME TAXES
Income (loss) before income taxes for the years ended December 31, 2024, 2023 and 2022 consists of the following:
Year ended December 31,
($ in millions)202420232022
Ireland$(292)$144 $298 
United States115 (264)(429)
Other countries193 (971)(164)
Income (loss) before income taxes $16 $(1,091)$(295)
The components of income tax expense for the year ended December 31, 2024, 2023 and 2022 consists of the following:
 Year ended December 31,
($ in millions)202420232022
Current:
Ireland$7 $44 $42 
U.S. federal(3)(1)— 
U.S. state4 6 (1)
Other countries194 203 179 
Total current tax expense202 252 220 
Deferred:
Ireland$2 $1 $(7)
U.S. federal(200)— — 
U.S. state(47)— — 
Other countries(103)(133)(138)
Total deferred tax (benefit)(348)(132)(145)
Total income tax (benefit) expense$(146)$120 $75 
There is no income tax (benefit) expense recognized in other comprehensive income for the years ended December 31, 2024, 2023 and 2022.
The reconciliation between the Irish statutory income tax rate, the trading income tax rate of our country of domicile, and our actual effective tax rate for the years ended December 31, 2024, 2023 and 2022 are as follows:
 Year ended December 31,
 202420232022
Irish corporation trading tax rate of
12.5 %(12.5)%(12.5)%
Depreciation on non-qualifying property and equipment8.9 %0.1 %(1.6)%
Effect of different statutory income tax rates in foreign jurisdictions226.0 %4.7 %(8.8)%
Non-deductible expenses230.5 %1.5 %9.8 %
Non-deductible expenses (non-taxable) Fox option expense (income)606.1 %3.6 %(3.9 %)
Non-taxable income(219.9)%(1.6)%(0.6)%
Recognition of deferred tax on internal asset transfers— %— %(16.5)%
Effect of changes in statutory income tax rates1.7 %0.1 %(0.8 %)
Change in valuation allowance(1444.5 %)12.1 %57.1 %
Under (over) provision in prior year(333.8 %)3.0 %3.2 %
Actual effective tax rate (912.5)%11.0 %25.4 %

The Group’s effective tax rate for the year ended December 31, 2024 is materially impacted by (i) the change in valuation allowance of $178 million, primarily related to the release in U.S. federal and state valuation allowance; (ii) favorable changes in provision to return adjustments; and (iii) the effect of expenses which are not deductible for income tax purposes. The Group’s effective tax rate for the year ended December 31, 2023 and 2022, was materially impacted by (i) change in valuation allowance (year ended December 31, 2023: $133 million; year ended December 31, 2022: $11 million) from our assessment of the future recoverability of deferred tax assets primarily in the U.S. and Netherlands; and (ii) the effect of expenses which are not deductible for income tax purposes.
The OECD is co-ordinating negotiations to implement a global minimum corporate tax of 15% for companies with global revenues and profits above certain thresholds (referred to as Pillar Two). Certain aspects of Pillar Two were effective from January 1, 2024 and other aspects are effective from January 1, 2025. For the year ended December 31, 2024 the Group incurred insignificant income tax expense in connection with Pillar Two. Under GAAP, the OECD Pillar Two rules are considered an alternative minimum tax and therefore deferred taxes were not recognized or adjusted for the estimated effects of the minimum tax.
The components of deferred tax assets (liabilities) were as follows as of December 31, 2024 and 2023:
 As of December 31,
($ in millions)20242023
Deferred tax assets
Property and equipment$39 $29 
Irish deferred amortization deductions65 34 
Share-based compensation44 63 
Net operating loss carryforwards850 881 
Other226 168 
Total deferred tax assets1,224 1,175 
Valuation allowance(878)(1,067)
Total deferred tax assets, net of valuation allowance346 108 
Deferred tax liabilities
Intangible assets(684)(886)
Total deferred tax liabilities(684)(886)
Net deferred tax liabilities$(338)$(778)

Deferred tax assets and liabilities have been offset at December 31, 2024 and 2023 to the extent they relate to the same tax-paying component. Included in the Consolidated Balance Sheets is a deferred tax asset of $267 million (December 31, 2023: $24 million) and a deferred tax liability of $605 million (December 31, 2023: $802 million).The movement in the valuation allowance balance differs from the amount in the effective rate reconciliation due to adjustments affecting balance sheet only items and foreign currency.
The deferred tax liability in relation to intangible assets disclosed above primarily relates to acquisition accounting-related intangibles. This deferred tax liability will unwind as the intangible assets are amortized over their useful economic life.
The deferred tax asset arising on share-based compensation relates to future tax deductions the Group expects to receive in relation to share-based payment plans operated by the Group to reward its employees. The asset is measured at the tax rate expected to apply when the temporary difference reverses.
The movement in the valuation allowance was comprised of the following as of December 31, 2024, 2023 and 2022:
 Year ended December 31,
($ in millions)202420232022
Balance Beginning of year$1,067 $1,069 $1,102 
Increase recognized in income tax expense80 172 83 
Decrease recognized in income tax expense(306)(39)(72)
Foreign currency translation adjustments(11)(56)(44)
Recognized in income tax expense - adjustment in relation to prior years48 — — 
Written off deferred tax assets— (79)— 
Net change in the valuation allowance(189)(2)(33)
Balance End of year$878 $1,067 $1,069 
For the year ended December 31, 2024, the Group recorded a net valuation allowance reduction of $178 million (comprising a valuation allowance release related to federal and state deferred tax assets of $247 million with respect to one of our key U.S. tax-paying components, $50 million tax benefit from current year utilization of deferred tax assets, partially offset by an increase in valuation allowance primarily due to current year operating losses in various jurisdictions). The valuation allowance release was the result of positive evidence of forecasted future taxable income and current year utilization of a portion of our deferred tax assets. The Group evaluates the realizability of its deferred tax assets each reporting period and establishes a valuation allowance to reduce deferred tax assets to the amount that is more-likely-than-not to be realized. The Group considers all available positive and negative evidence, including historical operating losses, future reversals of existing taxable temporary differences and tax planning strategies when evaluating the need for a valuation.
The Group has net operating loss carryforwards of $3,025 million as of December 31, 2024. Of these, $7 million expire between 2025 and 2033, $71 million expire between 2034 and 2043 and $2,947 million carry forward indefinitely. The Group considers all available positive and negative evidence, including historical operating losses, future reversals of existing taxable temporary differences and tax planning strategies when evaluating the need for a valuation allowance.
A valuation allowance has been recorded against deferred tax assets of $878 million (December 31, 2023: $1,067 million). This is on the basis that there is insufficient certainty of there being future taxable profits in the relevant jurisdictions and therefore the assets will not be realizable. The timing of recognition is a key area of judgement in the current period.
During the year ended December 31, 2023, the Group has written off deferred tax assets of $79 million relating to net operating loss carryforward. A full valuation allowance was previously recorded in relation to the deferred tax asset for these net operating loss carryforward and therefore there is no net effect of this within the income tax expenses for the year.
As of December 31, 2024, foreign earnings of $126 million have been retained by the Group’s foreign subsidiaries that meet the indefinite reinvestment reversal criteria and for which the related deferred tax liability has not been recognized. Upon repatriation of those earnings, in the form of dividends or otherwise, the Group could be subject to withholding taxes payable to various foreign countries of $9 million.
The following table presents a reconciliation of the total amounts of unrecognized tax benefits, excluding interest and penalties:
As of December 31,
($ in millions)202420232022
Unrecognized tax benefits at beginning of the year$129 $237 $188 
Increases for tax positions of prior years36 9 — 
Decreases for tax positions of prior years(2)(131)(1)
Increases for tax positions of the current year5 6 82 
Reductions to unrecognized tax benefits as a result of a lapse of the applicable statute of limitations(8)(3)(4)
Settlements(5)— (6)
Foreign currency translation adjustments(2)11 (22)
Unrecognized tax benefits at the end of the year$153 $129 $237 
Details of a tax dispute in relation to operations in Italy are provided in Note 21.
We have received a discovery assessment from His Majesty’s Revenue and Customs authority (“HMRC”) relating to an intragroup transfer of intellectual property from the United Kingdom to United States for the period ended December 31, 2020. As of December 31, 2024, we are in the process of appealing this assessment and recognized a liability for the estimated settlement which is included in the Group’s unrecognized tax benefits table. We do not expect to resolve this matter in the near term and will continue to reassess the recognition and measurement criteria of the tax position. While the Group believes that we have strong arguments, there can be no assurance this matter will be resolved favorably.
We recognize interest and penalties related to income taxes, if applicable, as income tax expense. The total amounts of interest and penalties recognized in the Consolidated Statements of Comprehensive (Loss) were $5 million (year ended December 31, 2023: $5 million; year ended December 31, 2022: $1 million). The total amounts of interest and penalties recognized in the Consolidated Balance Sheets were $10 million (year ended December 31, 2023: $9 million).
The total amount of unrecognized tax benefits that, if recognized, would affect the effective tax rate are $153 million.
It is reasonably possible that $11 million of unrecognized tax benefits may be recognized by the end of 2025 as a result of lapse of the statute of limitations.
In addition to filing federal and national income tax returns, the Group files income tax returns in numerous states and other subnational jurisdictions that impose an income tax. The Group is no longer subject to Irish taxing authority examination for years prior to 2020. Income tax years for 2021 onwards remain subject to examination by the U.S. federal Internal Revenue Service. Earlier periods will remain subject to examination by the Internal Revenue Service as the net operating losses from those years are utilized.