Module I· Deferred Taxes (DTA/DTL)Advanced
Question

How is DTA recoverability assessed — and what is the stress test?

Answer

IAS 12 and ASC 740 (and local GAAP equivalents) allow a DTA from loss carryforwards to be recognized only when realization is 'probable' (IFRS) / 'more likely than not' (US GAAP); local GAAP typically sets a similarly high evidentiary bar.

  • Historical profitability: With 3+ years of consistent taxable profits, the DTA can be fully recognized.
  • Forecast-based: If the management forecast for the next 3–5 years shows sufficient profits, the DTA can be recognized up to the usable losses.
  • Distressed situation: An operating loss pattern or an ongoing restructuring — the DTA cannot be recognized, or is reduced by a valuation allowance.
Deep diveShow more details
  • How sensitive is the DTA's recoverability to the forecast assumptions? A −200 bps margin loss — still recoverable?
  • Change-of-ownership risk on a future share transfer?
  • Time availability of the NOLs: unlimited carryforward in many jurisdictions; in the US, unlimited since 2018 but with an 80%-per-year cap.
  • Minimum-taxation rules in some jurisdictions: above an income threshold, only a portion (e.g. 60%) of income can be offset with NOLs — which slows utilization.

'The target DTA of $30m is, after our stress test (15% margin loss, 30% change-of-ownership risk), recoverable at $18m — with a corresponding discount in our EV-to-equity bridge'.