Since 1 January 1988, EDF and certain subsidiaries have formed a group subject to the tax consolidation system existing under French tax legislation (Articles 223A to 223U of the French Tax Code). The tax consolidation group comprises 267 subsidiaries in 2020, including Enedis, EDF International, EDF Renewables andDalkia.
Under Article 223A of the French Tax Code, EDF, as the head of the tax consolidated group, is the sole entity responsible for payment of income taxes and additional related contributions.
The tax consolidation agreement between the members of the tax group stipulates that the arrangement must be neutral in effect. In application of this principle, each subsidiary pays the consolidating company a contribution to group income tax equivalent to the tax it would have paid had it been taxed separately.
The tax consolidation agreement between EDF and the subsidiaries included in the tax group requires EDF to reimburse loss-making subsidiaries for the tax saving generated by their losses, as and when the entities concerned make taxable profits, in compliance with the standard rules for use of taxable losses.
The Company at the head of the tax group, EDF, recorded an income tax receivable of €406 million for 2020 (income tax receivable of €(605) million for 2019).
The breakdown is as follows:
Deferred taxes are not recognised in EDF’s individual financial statements. Deferred taxes result from differences between the accounting bases and tax bases of items. They generally arise as a result of timing differences in the recognition of income and expenses:
EDF SA, as head of the tax group, includes tax losses generated at Group level in its deferred tax positions.
Changes in the basis for deferred taxes are as follows:
(in millions of euros) | 31/12/2020 | 31/12/2019 | Variation |
---|---|---|---|
1. Timing differences generating a deferred tax asset | 1. Timing differences generating a deferred tax asset 31/12/2020
| 1. Timing differences generating a deferred tax asset 31/12/2019
| 1. Timing differences generating a deferred tax asset Variation
|
|
31/12/2020 (16,589) |
31/12/2019 (14 704) |
Variation (1,885) |
|
31/12/2020 (4,717) |
31/12/2019 (2,624) |
Variation (2,093) |
|
31/12/2020 (529) |
31/12/2019 (595) |
Variation 66 |
Total deferred tax assets subject to the standard rate | Total deferred tax assets subject to the standard rate 31/12/2020 (21,835) | Total deferred tax assets subject to the standard rate 31/12/2019 (17,923) | Total deferred tax assets subject to the standard rate Variation (3,912) |
2. Timing differences generating a deferred tax liability | 2. Timing differences generating a deferred tax liability 31/12/2020
| 2. Timing differences generating a deferred tax liability 31/12/2019
| 2. Timing differences generating a deferred tax liability Variation
|
|
31/12/2020 2,224 |
31/12/2019 2 256 |
Variation (32) |
|
31/12/2020 2,678 |
31/12/2019 2,547 |
Variation 131 |
Total deferred tax liabilities subject to the standard rate | Total deferred tax liabilities subject to the standard rate 31/12/2020 4,902 | Total deferred tax liabilities subject to the standard rate 31/12/2019 4,803 | Total deferred tax liabilities subject to the standard rate Variation 99 |
|
31/12/2020 - |
31/12/2019 - |
Variation - |
|
31/12/2020 (25) |
31/12/2019 (15) |
Variation (10) |
Total deferred tax assets subject to the reduced rate | Total deferred tax assets subject to the reduced rate 31/12/2020 (25) | Total deferred tax assets subject to the reduced rate 31/12/2019 (15) | Total deferred tax assets subject to the reduced rate Variation (10) |
BASIS FOR DEFERRED TAXES | BASIS FOR DEFERRED TAXES 31/12/2020 (16,958) | BASIS FOR DEFERRED TAXES 31/12/2019 (13,135) | BASIS FOR DEFERRED TAXES Variation (3,823) |
Net future tax asset at standard rate (2) | Net future tax asset at standard rate (2) 31/12/2020 4,510 | Net future tax asset at standard rate (2) 31/12/2019 3,369 | Net future tax asset at standard rate (2) Variation 1,141 |
Net future tax asset at reduced rate | Net future tax asset at reduced rate 31/12/2020 4 | Net future tax asset at reduced rate 31/12/2019 2 | Net future tax asset at reduced rate Variation 2 |
(1) Mainly concerning post-employment benefits for personnel. In 2020 these provisions also include unrealised tax savings resulting from the future deductibility of expenses whose deductibility is temporarily being questioned in ongoing tax litigations (see note 14).
(2) Applying a corporate income tax rate of 25.82% to long-term timing differences.