| (in millions of euros) | December 31, 2023 | December 31, 2022 |
|---|---|---|
| Deferred tax on adjustment of asset and liability valuations due to acquisitions | Deferred tax on adjustment of asset and liability valuations due to acquisitions December 31, 2023(36) |
Deferred tax on adjustment of asset and liability valuations due to acquisitions December 31, 2022(85) |
| Deferred tax arising on the restatement of the Champs-Élysées building | Deferred tax arising on the restatement of the Champs-Élysées building December 31, 2023(37) |
Deferred tax arising on the restatement of the Champs-Élysées building December 31, 2022(37) |
| Deferred tax on pensions and other post‑employment benefits | Deferred tax on pensions and other post‑employment benefits December 31, 202340 |
Deferred tax on pensions and other post‑employment benefits December 31, 202251 |
| Deferred tax arising on tax loss carryforwards | Deferred tax arising on tax loss carryforwards December 31, 2023344 |
Deferred tax arising on tax loss carryforwards December 31, 2022315 |
| Deferred tax on other temporary differences | Deferred tax on other temporary differences December 31, 2023143 |
Deferred tax on other temporary differences December 31, 202236 |
| Gross deferred tax assets (liabilities) | Gross deferred tax assets (liabilities)December 31, 2023454 | Gross deferred tax assets (liabilities)December 31, 2022280 |
| Unrecognized deferred tax assets | Unrecognized deferred tax assets December 31, 2023(340) |
Unrecognized deferred tax assets December 31, 2022(313) |
| Net deferred tax assets (liabilities) | Net deferred tax assets (liabilities)December 31, 2023114 | Net deferred tax assets (liabilities)December 31, 2022(33) |
As of December 31, 2023, deferred tax liabilities included the tax on the revaluation of intangible assets carried out at the time of the acquisition of Zenith (euro 5 million), Bcom3 (euro 41 million), Digitas (euro 12 million), Sapient (euro 38 million), Citrus (euro 10 million), Profitero (euro 6 million), as well as the deferred tax linked to the fair value being deemed as the cost of the Champs-Élysées land and building on the date of transition to IFRS.
The Group also had tax loss carryforwards that had not been recognized as deferred tax assets in the consolidated balance sheet because of uncertainty as to their availability for use:
| (in millions of euros) | December 31, 2023 | December 31, 2022 |
|---|---|---|
| Amount in unrecognized tax loss carryforwards | Amount in unrecognized tax loss carryforwardsDecember 31, 20231,142 | Amount in unrecognized tax loss carryforwardsDecember 31, 20221,105 |
| Of which carried forward indefinitely | Of which carried forward indefinitelyDecember 31, 2023 573 |
Of which carried forward indefinitelyDecember 31, 2022 507 |
The Group’s tax positions are based on its interpretations of tax regulations and past experience. Each position is assessed individually without offsetting or aggregation with other positions and gives rise to the recognition of a liability when an outflow of resources is deemed probable. The assessment of these tax liabilities corresponds to the best estimate of risk at the reporting date and, where appropriate, includes late‑payment interest and any penalties.
Liabilities relating to tax risks and litigation are recognized as tax liabilities for the companies for euro 216 million at December 31, 2023, versus euro 229 million at December 31, 2022.
From 2022, in the United States, Tax Cuts and Jobs Act requires capitalization and amortization of research & development expense (over five years for US expenditures), largely affecting Tech & IT companies. The application of this new tax measure was confirmed in December 2022.
This tax evolution has no impact on the effective tax rate, while cash tax payments will be increased over the first five years. The increase of the current tax charge will be neutralized by the recognition of a deferred tax asset for the same amounts.
