Table:
|  | 31 March 2019 | 31 March 2018 Restated See note 2 |
| --- | --- | --- |
|  | $M | $M |
| Deferred income tax assets in relation to: |  |  |
| Deferred revenue | 40.9 | 40.0 |
| Tax value of carry forward losses of UK subsidiaries | 37.0 | 24.2 |
| Tax value of carry forward losses of overseas subsidiaries | 6.2 | 6.4 |
| Advanced capital allowances | 7.5 | 7.7 |
| Share-based payments | 11.6 | 27.7 |
| Other temporary differences | 11.8 | 14.7 |
| Total | 115.0 | 120.7 |
| Deferred income tax liabilities in relation to: |  |  |
| Intangible assets | 6.1 | 5.9 |
| Deferred selling cost | 8.5 | 8.5 |
| Other temporary differences | - | 0.1 |
| Total | 14.6 | 14.5 |
Paragraphs:
Expected Future Rate
Over the medium-term the tax rate is likely to stabilise as the integration of acquisitions in higher rate jurisdictions are completed. However, the tax rate may fluctuate if business changes are implemented in response to legislation arising from the OECD’s Base Erosion & Profit Shifting Project. Legislative change in key territories is being monitored and acted upon.
The Group does not anticipate any significant impact on the future tax charge, liabilities or assets, as a result of the triggering of Article 50(2) of the Treaty on European Union, but cannot rule out the possibility that, for example, a failure to reach satisfactory arrangements for the UK’s future relationship with the European Union, could have an impact on such matters.
The European Commission has concluded its investigation into the UK’s controlled foreign company (“CFC”) rules. The CFC rules levy a charge on foreign entities controlled by the UK that are subject to a lower rate of tax, however there is currently an exemption available for 75% of this charge if the activities being undertaken by the CFC relate to financing. The EC concluded that this exemption is in breach of EU State Aid rules. However, whilst we are awaiting further detail from HMRC, the position has not changed from a tax accounting perspective. The risk is possible, but not probable. UK ministers have yet to decide on whether to pursue an appeal. No provision for this potential liability of $3.6M has been provided in these Consolidated Financial Statements as it is not clear what, if any, the ultimate financial result will be.
Deferred tax assets and liabilities are attributable to the following:
As at 31 March 2019 the aggregate amount of temporary differences associated with undistributed earnings of subsidiaries for which deferred tax liabilities have been recognised was $Nil (2018: $Nil). No liability has been recognised because the Group is in a position to control the reversal of temporary differences and it is probable that such differences will not reverse in the foreseeable future.
Deferred tax assets and liabilities are measured at the tax rates that are expected to apply in the period when the asset is realised or the liability settled, based on tax rates that have been enacted or substantively enacted at the reporting date.
Question:
In what situations can the tax rate fluctuate?