|
|
|
|
The estimated tax (expense) benefit consists of the following:
| |
Years
ended September 30,
|
| |
1999
|
1998
|
1997
|
|
|
(Thousands
of U.S. dollars)
|
|
Current
income tax
|
-
|
(126)
|
(747)
|
| Business
assets tax |
(320)
|
(1.222)
|
(468)
|
|
Deferred
income tax
|
10
|
(935)
|
5.005
|
|
Total
tax benefit (expense)
|
(310)
|
(2.283)
|
3.790
|
|
Income tax -
For the Venezuelan subsidiaries differences between the amount
of income taxes computed at the statutory regular tax rate of
34% and the effective income tax rates for the years result from
inflation-adjustments for Venezuelan tax purposes described below,
dividends from subsidiaries, intercompany transactions, income
from foreign sources and the requirement that Venezuelan income
taxes be based on the underlying bolivar accounts of each Venezuelan
company on an individual basis as follows:
| |
Years
ended September 30,
|
| |
1999
|
1998
|
1997
|
|
|
%
|
%
|
%
|
|
Statutory
income tax rate (%)
|
34,0
|
(126)
|
(747)
|
| Increase
(decrease) in tax rate resulting from: |
|
|
|
|
Remeasurement
into U.S. dollars for accounting purposes and effect
of taxes assessed in bolivars
|
55,5
|
64,3
|
(6,0)
|
|
Inflation
adjustment for tax purposes
|
(66,6)
|
(79,1)
|
(46,1)
|
| Non
taxable income |
(15,5)
|
(0,6)
|
-
|
| Other,
net |
(9,6)
|
(5,4)
|
0,4
|
| Effective
income tax rate (%) |
(2,2)
|
13,2
|
(17,7)
|
|
For the Venezuelan subsidiaries, beginning in fiscal 1993, an
annual inflation-adjustment is required which may result in an
increase or decrease in taxable income. The Venezuelan Tax Law
provided that the new values resulting from the inflation adjustments
are to be depreciated over the remaining useful lives of the fixed
assets. In accordance with SFAS N° 109, no deferred tax asset
was recorded for the future benefits of the inflation adjustments.
The Cayman Islands levy no taxes on income, dividends or capital
gains.
As a result of the Fior contributions and transfers of assets
(see Note 1), under Venezuelan Tax Law the tax basis of the property,
plant and equipment transferred by Fior was increased. Such increase
is not recorded in the financial statements. However, a deferred
tax asset of US$4.8 million was recorded during 1997 to recognize
the future Venezuelan tax benefit of the additional depreciation.
This asset was included in the transfer of assets indicated in
Note 1.
The Venezuelan Income Tax Law provides for tax losses and tax
credits from new investments to be carried forward over the following
three years, to reduce income taxes payable. At September 30,
1999, IBH's subsidiaries had tax loss carry-forwards amounting
to Bs 3,404 million (equivalent to US$5.4 million), of which Bs
808 million is available to offset taxable income until the end
of fiscal 2002, Bs 2,493 million until the end of fiscal 2001
and Bs 103 million until the end of fiscal 2000. IBH's subsidiaries
also had investment tax credits amounting to Bs 1,553 million
(equivalent to US$2.5 million) at September 30, 1999, of which
Bs 1,548 million may be applied against income tax liability until
the end of fiscal 2002 and Bs 5 million until the end of fiscal
2001. Utilization of these tax loss carry-forwards and investment
tax credits is dependent on realizing future taxable income in
the appropriate company. Deferred tax assets relating to these
tax loss carry-forwards and investment tax credit have been reduced
by a valuation allowance representing the portion of those assets
for which it is more likely than not they will not be realized.
Changes in the valuation allowance from year to year were due
to changes in the amounts of deferred tax assets to which it relates.
The components of net deferred income tax assets (liability) are
as follows:
| |
As of September 30,
|
| |
1999
|
1998
|
|
|
(Thousands
of U.S. dollars)
|
|
Investments
tax credits
|
2.473
|
29
|
| Tax
loss carry-forwards |
1.844
|
1.935
|
|
Business
assets tax credits
|
2.160
|
1.251
|
|
Uncollected
income from draw backs
|
(624)
|
(680)
|
| Allowances
and provisions not deductible until paid |
774
|
815
|
| Other
, net |
89
|
80
|
| |
6.716
|
3.430
|
| Valuation
allowance |
(6.722)
|
(3.446)
|
| Net
deferred income tax liability, include in other liabilities |
(6)
|
(16)
|
|
Business assets tax
The Venezuelan business assets tax was enacted as a supplementary
tax to the Venezuelan income tax and is calculated on the basis
of the simple average of the taxpayer's tangible and intangible
assets situated in Venezuela which were involved in the production
of income from commercial and industrial activities. The tax rate
applicable to the asset base is 1% a year, reduced by the percentage
of export sales to total sales. This tax and the income tax are
calculated together and the greater of the two is the tax liability.
A business asset tax expense of US$320,000 was recorded during
the year ended September 30, 1999 (US$1,222,000 in 1998). The
payment of this tax may be applied as a tax credit against any
income tax liability incurred over the next three fiscal years.
Wholesale and luxury tax
In 1994 the Wholesale and Luxury Tax (ICSVM) Decree-Law was enacted.
This tax is based on a tax credit system and applies to the different
stages of production and sales. It is payable based on the value
added at each stage. This system incorporated additional tax rates
of 10% and 20% over goods and services considered as luxury items.
The ICSVM tax rate was set annually in the Budget Law, which until
May 1999 was 16.5%. The Law provides for a special tax rate (0%)
for exporters, granting them the right to recover tax credits
from the purchase or import of goods and services based on the
ratio of export sales to total sales.
In May 1999 the Venezuelan government, through a Decree-Law, repealed
and substituted the ICSVM tax for the value added tax (VAT). The
VAT tax kept the same ICSVM structure, but certain changes were
made, namely: 1) the applicable tax rate, which was set at 15.5%
for 1999, effective as from June 1; 2) the elimination of additional
tax rates and; 3) modification of the system for the recovery
of credits by exporters, including the possibility of offsetting
or transferring tax credits when the tax administration does not
provide a decision within the term set forth; the special tax
rate (0%) for exporters is still applied.
At September 30, 1999, accounts receivable include tax credits
of some US$4,662,000 (US$3,215,000 in 1998) from the value added
tax and wholesale and luxury tax (see Note 3), of which US$3,984,000
(US$2,393,000 in 1998) correspond to recoverable credits from
export operations.
Bank debit tax
In May 1999 the Venezuelan government, through a Decree-Law, enacted
the bank debit tax, which mainly levies debits or withdrawals
made on current and savings accounts, custody deposits, or on
any other type of demand deposit. Bank debit tax is also applied
to liquid assets funds, trust funds and other financial market
funds or financial instruments transacted by individuals or corporations
with Venezuelan banks and financial institutions. The bank debit
tax amounts to 0.5% and will be in effect for one year. In the
year ended September 30, 1999, IBH incurred in bank debit tax
expenses amounting to Bs 67 million (equivalent to US$109,000).
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