16. Deferred tax assets and liabilities

(in millions of euros)

net balance as at 1 January 2015

Recognised in incomestatement

Recognised in total result

Other changes

Net position

Deferred tax assets

Deferred tax liabilities

     

Position as at 31 December 2015

Property, plant and equipment

-92

-8

-

-9

-109

38

147

Intangible assets

-4

-3

-

-

-7

-

7

Financial fixed assets

-8

-3

-

-

-11

-

11

Receivables

31

-31

-

-

-

-

-

Provisions

1

-1

-

-

-

-

-

Deferred credits

35

38

-

-

73

73

-

Loans and other financial liabilties

14

3

-4

-

13

13

-

Other items

-1

-4

-

4

-1

2

3

Loss compensation

150

-

-

2

152

152

-

Deferred tax assets (liabilities)

126

-9

-4

-3

110

278

168

        
        

(in millions of euros)

net balance as at 1 January 2016

Recognised in incomestatement

Recognised in total result

Other changes

Net position

Deferred tax assets

Deferred tax liabilities

     

Position as at 31 December 2016

Property, plant and equipment

-109

-8

-

-1

-118

23

141

Intangible assets

-7

-

-

-2

-9

-

9

Financial fixed assets

-11

9

-2

1

-3

4

7

Receivables

-

-

-

-

-

-

-

Provisions

-

3

-3

1

1

2

1

Deferred credits

73

-9

-

1

65

65

-

Loans and other financial liabilities

13

-1

-6

-2

4

4

-

Other items

-1

-

-

-1

-2

-

2

Loss compensation

152

-21

-

-

131

131

-

Deferred tax assets (liabilities)

110

-27

-11

-3

69

229

160

    The ‘Other changes’ are due to alterations to the fiscal position as a result of submitting the tax return.

    Net operational losses that have been categorised as tax losses under Dutch tax law and that arose in the Dutch subsidiaries can in general be settled against future profits achieved during the nine years after the year in which the loss was suffered, and can be settled against profits made in the year preceding the loss-making year. There are comparable rules for the positions in foreign enterprises.

    As at 31 December 2016, the Group had deferred tax assets for downward valuations amounting to €272 million for the fiscal unity in the Netherlands. These deferred tax assets are partly covered by deferred tax liabilities that produce taxable profits in the reference period through to 2024 and forecast profits through to 2024, based on the Concern Plan 2017-2021. The forecasts assume the current breakdown of the Group’s activities, taking account of the main rail network concession, which started on 1 January 2015. On top of that, the Group has tax planning possibilities that can be implemented if necessary. Because the forecasts through to 2024 have an inherent margin of uncertainty, €67 million of the sum has not been valued (31 December 2015 : €67 million).The net deferred tax assets of the fiscal unity in the Netherlands therefore amount to €205 million (31 December 2015 : €246 million).

    A rate of 25% applied in 2016 for Dutch corporate income tax (25% in 2015). For the calculation of the deferred tax position of the Dutch entities, the applicable rate of 25% has been assumed. The Dutch tax authorities are currently investigating the fiscal handling of transactions with the Irish subsidiary, NS Financial Services. The investigation is focusing inter alia on the classification of the leasing agreements signed between NS and NS Financial Services; this relates to the years from 2013 onwards. The conduct of NS since these agreements were signed has been consistent in this regard; any other opinion about the eligibility of the lease agreements could have a material impact on the tax burden. On the tax returns up to 2012, there is agreement with the tax authorities.