4.4 Legal risk - Scor

In 2010 the tax rate change impact resulted from a new tax law in France and the revaluation of deferred taxes for UK
companies due to the change of the UK income tax rate from 28% to 27% effective April 2011.
In December 2010, the French Parliament enacted a new tax law regarding the taxation of the French capitalization reserve
(“reserve de capitalization”, a French insurance statutory provision). As a result French insurance companies have to pay a
10% exit tax on the capitalization reserve position as at 31 December 2009. In return any increase or release of the
capitalization reserve is no longer taken into consideration in the calculation of income taxation from 1 January 2010
onwards. Therefore, there is no longer any deferred tax impacts to be considered.
The existing deferred tax liabilities related to this position measured at 34.43% were released, resulting in a net tax benefit
of 24.43% of the capitalization reserve as at 31 December 2009. Therefore, the income tax expense for the year 2010
includes a benefit of EUR 42 million for the change in tax law.
In the Finance Bill 2013 an additional 7% exit tax on the capitalization reserve position as at 31 December 2009 was
enacted resulting in an additional income tax expense in the year 2012 of EUR 12 million. Changes in tax risk provision are
included within Other Liabilities.
The standard tax rates for the primary locations in which the Group has operations are as follows:
2012 2011 2010
France 36.10% 36.10% 34.43%
Switzerland 21.17% 21.17% 21.17%
Germany 32.45% 32.45% 31.58%
United Kingdom 24.50% 25.50% 28.00%
United States 35.00% 35.00% 35.00%
Singapore 17.00% 17.00% 17.00%
INCOME TAX EFFECTS RELATING TO OTHER COMPREHENSIVE INCOME
Before
tax
amount
2012 2011 2010
Net of Before Tax Net of Before
tax tax (expense) tax tax
amount amount benefit amount amount
Tax
(expense)
benefit
Tax
(expense)
benefit
Net of
tax
amount
In EUR million
Effect of changes
in foreign
exchange rates (20) 8 (12) 117 - 117 136 - 136
Revaluation of
assets available
for sale 331 (98) 233 (307) 82 (225) 87 (25) 62
Shadow
accounting 8 3 11 (4) (4) (8) (67) 24 (43)
Net gains /
losses on cash
flow hedge (25) 6 (19) (21) 3 (18) - - -
Actuarial gains /
losses not
recognized in
income (17) 8 (9) (5) 7 2 (14) 6 (8)
Other changes 2 - 2 1 (5) (4) 2 - 2
TOTAL 279 (73) 206 (219) 83 (136) 144 5 149
260