| Deferred tax assets and liabilities |
23 Deferred tax assets and liabilities | December 31, 2025 | December 31, 2024 | Deferred tax liabilities before offsetting | 6,937 | | Deferred tax assets available for offset | (2,132) | (3,143) | | 4,805 | | Deferred tax assets before offsetting (net of accumulated write-down provisions) | 8,848 | | Deferred tax liabilities available for offset | (2,132) | (3,143) | | | |
The most significant temporary differences giving rise to net deferred tax assets and liabilities are disclosed below: | | | | | | Accelerated tax depreciation | | | | | | Site restoration and abandonment (tangible assets) | | | Difference between the fair value and the carrying amount of assets acquired | | | Derivative financial instruments | | | Application of the weighted average cost method in evaluation of inventories | | | | 1,288 | | | 6,937 | | | | | | (4,746) | (5,018) | Site restoration and abandonment (provisions for contingencies) | (1,953) | (2,148) | Timing differences on depreciation and amortization | (1,738) | (1,847) | Accruals for impairment losses and provisions for contingencies | (1,329) | (1,432) | | (1,378) | (1,320) | Derivative financial instruments | (104) | (352) | | (268) | (338) | | (134) | (151) | | (89) | (120) | Unrealized intercompany profits | (71) | (77) | | (1,193) | (1,313) | | (13,003) | (14,116) | Accumulated write-downs of deferred tax assets | 4,155 | | Deferred tax assets, net of accumulated write-downs | (8,848) | (9,465) |
The following table summarizes the changes in deferred tax liabilities and assets: | Deferred tax liabilities before offsetting | Deferred tax assets before offsetting, gross | Accumulated write-downs of deferred tax assets | Deferred tax assets before offsetting net of accumulated write-down provisions | | | (14,116) | | (9,465) | | 506 | (2,628) | | (2,100) | | (600) | | (60) | | Changes with effect to OCI | | | | | Currency translation differences | (897) | | (245) | | Change in scope of consolidation | | | | | | (874) | 1,417 | (719) | 698 | | 6,937 | (13,003) | 4,155 | (8,848) | | | (13,909) | | (8,241) | | | (1,862) | | (1,405) | | (1,042) | | (1,663) | | Changes with effect to OCI | (351) | | | | Currency translation differences | | (384) | | (263) | Change in scope of consolidation | | | (168) | (12) | | | (385) | | (149) | | | (14,116) | | |
Carry-forward tax losses amounted to €18,575 million, of which €15,432 million can be carried forward indefinitely. Carry-forward tax losses were €10,841 million at Italian subsidiaries and €7,734 million at foreign subsidiaries. Deferred tax assets gross of accumulated write-downs recognized on these losses amounted to €2,602million and €2,144 million, respectively. The Italian tax law allows the carry-forward of tax losses indefinitely. Foreign tax laws generally allow the carry-forward of tax losses over a period longer than five years, and in many cases, indefinitely. A tax rate of 24% was applied to tax losses of Italian subsidiaries to determine the portion of the carry-forwards tax losses. The corresponding average rate for foreign subsidiaries was 27.7%. Accumulated write-downs of deferred tax assets related to Italian companies for €2,134 million and non-Italian companies for €2,021 million. Taxes are also described in note 33 – Income taxes.
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