| Taxation |
27. Taxation The Group’s income tax expense recognized in the consolidated
statement of profit or loss and other comprehensive loss was as follows:
| | |
2022 | | |
2021 | | |
2020 | |
| Deferred income tax expense | |
| (52,004 | ) | |
| (570,730 | ) | |
| (389,384 | ) |
| Deferred income tax gain | |
| 62,332 | | |
| 549,110 | | |
| 410,668 | |
| Income tax gain/(loss) | |
| 10,329 | | |
| (21,620 | ) | |
| 21,284 | |
The Group’s effective income tax expense differed from the expected
theoretical amount computed by applying the Group’s applicable weighted average tax rate of 13.7% in 2022 (2021: 13.5%, 2020: 12.1%)
as summarized in the following table:
| Reconciliation | |
2022 | | |
2021 | | |
2020 | |
| Loss before income tax | |
| (26,538,740 | ) | |
| (17,036,823 | ) | |
| (8,221,449 | ) |
| Income tax at statutory tax rates applicable to results in the respective countries | |
| 3,641,775 | | |
| 2,348,057 | | |
| 991,120 | |
| Effect of unrecognized temporary differences | |
| (125,260 | ) | |
| (632,031 | ) | |
| (302,557 | ) |
| Effect of unrecognized taxable losses | |
| (3,015,088 | ) | |
| (1,885,486 | ) | |
| (184,881 | ) |
| Effect of impairment of assets | |
| — | | |
| (75,375 | ) | |
| — | |
| Effect of previously unrecognized deferred tax asset | |
| — | | |
| — | | |
| 97,458 | |
| Effect of expenses not considerable for tax purposes | |
| — | | |
| — | | |
| (47,894 | ) |
| Effect of impact from application of different tax rates | |
| (491,098 | ) | |
| 223,215 | | |
| (531,962 | ) |
| Income tax gain/(loss) | |
| 10,329 | | |
| (21,620 | ) | |
| 21,284 | |
The tax effect of taxable temporary differences
that give rise to deferred income tax liabilities or to deferred income tax assets as of December 31 is presented below:
| | |
December 31, | | |
December 31, | |
| Deferred Tax Liabilities | |
2022 | | |
2021 | |
| Intangible assets | |
| — | | |
| (51,914 | ) |
| Deferred unrealized foreign exchange gains | |
| — | | |
| — | |
| Other receivables | |
| (167,299 | ) | |
| (122,449 | ) |
| Total | |
| (167,299 | ) | |
| (174,363 | ) |
| | |
December 31, | | |
December 31, | |
| Deferred Tax Asset | |
2022 | | |
2021 | |
| Net operating loss (NOL) | |
| 41,429 | | |
| 31,879 | |
| Total | |
| 41,429 | | |
| 31,879 | |
| Deferred Tax, net | |
| (125,870 | ) | |
| (142,484 | ) |
| | |
Opening | | |
Recognized in | | |
Recognized in | | |
Exchange | | |
Closing | |
| Deferred Tax 2022 | |
Balance | | |
Profit or Loss | | |
Equity | | |
Differences | | |
Balance | |
| Intangible assets | |
| (51,914 | ) | |
| 51,958 | | |
| — | | |
| (44 | ) | |
| — | |
| Other receivables | |
| (122,449 | ) | |
| (52,004 | ) | |
| — | | |
| 7,154 | | |
| (167,299 | ) |
| Net operating loss (NOL) | |
| 31,879 | | |
| 10,374 | | |
| — | | |
| (825 | ) | |
| 41,429 | |
| Total | |
| (142,484 | ) | |
| 10,329 | | |
| — | | |
| 6,285 | | |
| (125,870 | ) |
| | |
Opening | | |
Recognized in | | |
Recognized in | | |
Exchange | | |
Closing | |
| Deferred Tax 2021 | |
Balance | | |
Profit or Loss | | |
Equity | | |
Differences | | |
Balance | |
| Intangible assets | |
| (252,174 | ) | |
| 199,056 | | |
| — | | |
| 1,204 | | |
| (51,914 | ) |
| Deferred unrealized foreign exchange gains | |
| (350,054 | ) | |
| 350,054 | | |
| — | | |
| — | | |
| — | |
| Derivative financial asset | |
| — | | |
| (127,000 | ) | |
| — | | |
| 4,551 | | |
| (122,449 | ) |
| Net operating loss (NOL) | |
| 476,363 | | |
| (443,730 | ) | |
| — | | |
| (754 | ) | |
| 31,879 | |
| Total | |
| (125,865 | ) | |
| (21,620 | ) | |
| — | | |
| 5,001 | | |
| (142,484 | ) |
As of December 31, 2022,
the Group had unrecognized tax loss carryforwards amounting to CHF 103.1 million (2021: CHF 109.9 million), of which CHF 101.4 million
related to Auris Medical AG, Otolanum AG, Zilentin AG and Altamira Medica AG in Switzerland, CHF 1.7 million to Altamira Therapeutics
Inc. in the United States (2021: CHF 108.6 million for Auris Medical AG, Otolanum AG, Zilentin AG and Altamira Medica AG and CHF 1.3 million
for Auris Medical Inc.). The Group’s unrecognized tax loss carryforwards with
their expiry dates are as follows:
| | |
December 31, | | |
December 31, | |
| | |
2022 | | |
2021 | |
| Within 1 year | |
| 27,956,899 | | |
| 28,909,896 | |
| Between 1 and 3 years | |
| 31,668,498 | | |
| 50,673,943 | |
| Between 3 and 7 years | |
| 41,797,708 | | |
| 29,007,049 | |
| More than 7 years | |
| 1,691,572 | | |
| 1,264,262 | |
| Total | |
| 103,114,677 | | |
| 109,855,150 | |
Due to the uncertainty surrounding
the future results of operations and the uncertainty as to whether the Group can use the loss carryforwards for tax purposes, deferred
tax assets on tax loss carryforwards were only considered to the extent that they offset taxable temporary differences within the same
taxable entity. No deferred tax assets are calculated on temporary differences related to pension obligations from IAS 19. The tax effect of the major unrecognized temporary differences
and loss carryforwards is presented in the table below:
| | |
December 31, | | |
December 31, | |
| | |
2022 | | |
2021 | |
| Deductible temporary differences | |
| | |
| |
| Deferred income | |
| 111,025 | | |
| — | |
| Employee benefit plan | |
| 43,841 | | |
| 87,149 | |
| Other accounts payable | |
| — | | |
| 344,822 | |
| Total potential tax assets | |
| 154,866 | | |
| 431,971 | |
| Potential tax assets from loss carry-forwards not recognized | |
| 13,297,723 | | |
| 14,271,306 | |
| Total potential tax assets from loss carry-forwards and temporary differences not recognized | |
| 13,452,589 | | |
| 14,703,277 | |
|