Financial years subject to tax inspection
The last four financial years of the Tax Consolidation Group are open to inspection in accordance with Spanish tax legislation.
Regarding the financial years open to inspection, contingent liabilities not susceptible to objective quantification may exist, which are not significant in the
opinion of the Group’s Directors.
Deductions applied by the consolidated tax group of the Parent Company
The deductions generated during the year are essentially due to double taxation.
At 31 December 2012, the Tax Group held the following tax credits carryforward (€ thousand):
Year of origin
Deduction pending application
Amount
2002
to 2010
Investment in export activity
29,047
2006
to 2012
Tax deduction to avoid double taxation
15,123
2002
to 2012
Others
472
44,642
Similarly, the consolidated tax group of the Parent Company took advantage in prior years of the “Deferral of extraordinary profits for reinvestment” scheme.
The essential characteristics of such reinvestment are as follows (€ thousand):
Amount offset
Year of origin Revenue qualifying for deferral
Previous years
Year 2012
Amount Outstanding Last year of deferral
1999
75,145
49,393
682
25,070
2049
All these revenues were reinvested through various financial interests, except for those originating in 1999, which were reinvested in the acquisition of real
estate.
Revenue from previous year deducted for the reinvestment of extraordinary profits, in accordance with the provisions set forth in Article 42 of the Revised Text
of the Corporate Income Tax Act, is shown below (€ thousand).
Financial year
Date of
transmission
Revenue
deferred
Deduction
Company
generating the capital gain
Company
reinvesting
Applied Outstanding
2008
June
1.583
-
190
Gran Círculo de Madrid, S.A.
NH Europa, S.L.
The capital gains obtained in 2008 were re invested in 2009 through the acquisition of new shares in the Italian subsidiary through NH Europa, S.L., formerly
“
NH Hotel Rallye, S.A.” These shares were issued as a result of a capital increase of €73 million, allocated to acquiring new hotels and refurbishing existing
ones, with an obligation to maintain the investment during a three year period.
Negative tax bases
At year-end, the Italy Business Unit has €20,511 thousand in tax losses carryforwards, which do not have an expiry date.
At 31 December 2012, the consolidated tax group of which NH Hoteles, S.A. is the parent company has the following tax loss carry-forwards:
Financial year
€ Thousand
Maturity
2007
8,992
2025
2008
20,424
2026
2009
96,752
2027
2010
74,173
2028
2011
47,415
2029
2012
192,759
2030
Total
440,515
NH Central Reservation Office, S.L. (formerly called Retail Invest, S.A.); Latinoamericana de Gestión Hotelera, S.A.,; Hoteles Hesperia, S.A.; Nuevos Espacios
Hoteleros S.A. and Club Deportivo Sotogrande, S.A. obtained negative tax bases before their incorporation into the Group of which NH Hoteles, S.A. is the
parent company.
The amounts of the above-mentioned tax loss carry-forwards that can only offset positive results of the aforementioned companies when the Group obtains
a positive tax base, are as follows (€ thousand):
98
REPORT ON THE CONSOLIDATED
FINANCIAL STATEMENTS
