MILLIRE ENG2024
In September 2023, the Public Oversight, Accounting, and Auditing Standards Authority (KGK) published amendments to TAS 12, which introduced a mandatory exception regarding the recognition and disclosure of deferred tax assets and liabilities related to Pillar Two income taxes. These changes were implemented to apply the rules of the OECD’s Pillar Two Model to tax laws that have been enacted or are close to being enacted, ensuring that income arising from such tax laws is subject to TAS 12. The amendments also introduce specific disclosure requirements for businesses affected by these tax laws. The exception, stating that information about deferred taxes under these laws will neither be recognized nor disclosed, applies as of the publication of the amendment. The Pillar Two regulations, which have been agreed upon by OECD member countries, came into effect in Turkey with the publication of Law No. 7524 on August 2, 2024, in the Official Gazette, amending certain tax laws and the Decree Law No. 375. While secondary legislation has not yet been issued, preliminary assessments, taking into account the regulations published by the OECD, suggest that these regulations are not expected to have any impact on the financials. However, legislative changes in Turkey and the other countries in which the company operates are being closely monitored. With the laws published in the Official Gazette dated August 2, 2024, the Domestic Minimum Corporate Tax has been enacted. This tax will be applied starting from the 2025 fiscal year. The “Minimum Corporate Tax” provision introduced by Law No. 7524 stipulates that the calculated corporate tax, before any deductions and exemptions, cannot be less than 10% of the corporate income. This regulation will come into effect as of the publication date to be applied to corporate income for the 2025 taxation period. Additionally, the 23 rd Corporate Tax General Communiqué has been published regarding this matter. Transfer pricing In Turkey, the transfer pricing provisions have been stated under the Article 13 of Corporate Tax Law with the heading of “disguised profit distribution via transfer pricing”. The General Communiqué on disguised profit distribution via Transfer Pricing, dated November 18, 2007 sets details about implementation. If a taxpayer enters into transactions regarding sale or purchase of goods and services with related parties, where the prices are not set in accordance with arm’s length principle, then related profits are considered to be distributed in a disguised manner through transfer pricing. Such disguised profit distributions through transfer pricing are not accepted as tax deductible for corporate income tax purposes. Deferred tax In accordance with TAS 12 - Income taxes , deferred tax assets and liabilities are recognized on all taxable temporary differences arising between the carrying values of assets and liabilities in the financial statements and their corresponding balances considered in the calculation of the tax base, except for the differences not deductible for tax purposes and initial recognition of assets and liabilities which affect neither accounting nor taxable profit. Deferred tax assets and liabilities are reported as net in the financial statements if, and only if, the Company has a legally enforceable right to offset current tax assets against current tax liabilities and the deferred tax assets and deferred tax liabilities relate to income taxes levied by the same taxation authority on either the same taxable entity. If the valuation differences resulting from the valuation of assets are recognized in the income statement, the corporate income tax and deferred tax income or expense related to them are also recognized in the income statement. If the valuation differences resulting from the valuation of the related assets are directly accounted for in the equity accounts, the related tax effects are also directly accounted for in the equity accounts. Temporary taxes are paid by calculating the corporate tax rate to which their earnings are subject that year. Temporary taxes paid during the year can be deducted from the corporate tax calculated on the annual corporate tax return of that year. As of December 31, 2024, the applicable corporate tax rate is 30%, therefore 30% tax rate was used for the calculation. (December 31, 2023: 30%) 2.19 Employee benefits Pension and other post-retirement obligations A defined benefit plan is a pension plan that defines an amount of pension benefit that an employee and his/her dependants will receive on retirement, usually dependent on one or more factors such as age, years of service and compensation. Employees of the Company are the members of “Milli Reasürans Türk Anonim Şirketi Emekli ve Sağlık Sandığı Vakfı (“Milli Reasürans Pension Fund”) which is established in accordance with the temporary Article 20 of the Social Security Act No: 506. 121 2024 Annual Report Millî Reasürans Türk Anonim Şirketi (Currency: Turkish Lira (TL)) Notes to the Unconsolidated Financial Statements As of December 31, 2024 (Convenience Translation of Financial Statements and Related Disclosures and Footnotes Originally Issued in Turkish) GENERAL INFORMATION FINANCIAL RIGHTS PROVIDEDTOTHE MEMBERS OF THE GOVERNING BODY AND SENIOR EXECUTIVES RISKS AND ASSESSMENT OF THE GOVERNING BODY ACTIVITIES AND MAJOR DEVELOPMENTS RELATED TO ACTIVITIES RESEARCH & DEVELOPMENT ACTIVITIES FINANCIAL STATUS FINANCIAL INFORMATION
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