Income Taxes (Tables)
|
12 Months Ended |
Dec. 31, 2024 |
Income Tax Disclosure [Abstract] |
|
Components of loss (income) before income taxes |
The components of the Company's loss (income) before income taxes are as follows:
|
|
|
|
|
|
|
|
|
|
December 31, 2024 |
|
December 31, 2023 |
|
UK |
$ |
|
171,670,156 |
|
$ |
|
29,427,631 |
|
US |
|
|
696,137 |
|
|
|
994,933 |
|
Spain |
|
|
262,064 |
|
|
|
298,927 |
|
India |
|
|
(88,448 |
) |
|
|
(92,982 |
) |
Taiwan |
|
|
61,948 |
|
|
|
44,181 |
|
Total |
$ |
|
172,601,857 |
|
$ |
|
30,672,690 |
|
|
Current and Deferred Income Tax Expense |
Current and deferred income tax expense consist of:
|
|
|
|
|
|
|
|
|
|
December 31, 2024 |
|
December 31, 2023 |
|
|
|
|
|
|
|
|
India |
$ |
|
44,933 |
|
$ |
|
63,408 |
|
Total |
$ |
|
44,933 |
|
$ |
|
63,408 |
|
Current |
|
|
44,933 |
|
|
|
63,408 |
|
Total |
$ |
|
44,933 |
|
$ |
|
63,408 |
|
|
Reconciliation of the federal income tax rate to the company's effective tax rate |
Income tax benefit attributable to our loss before income taxes differs from the amounts computed using the applicable income tax rate as a result of the following factors:
|
|
|
|
|
|
|
|
|
|
|
December 31, 2024 |
|
|
December 31, 2023 |
|
Loss before income taxes |
$ |
|
(172,601,857 |
) |
$ |
|
(30,672,690 |
) |
Income tax benefit at statutory tax rates (a) |
|
|
43,150,464 |
|
|
|
7,208,082 |
|
Effect of: |
|
|
|
|
|
|
Non-deductible or non-taxable foreign currency exchange results |
|
|
(329,399 |
) |
|
|
(88,195 |
) |
International rate differences (b) |
|
|
(23,423 |
) |
|
|
(9,845 |
) |
Non-deductible expenses |
|
|
(29,893,933 |
) |
|
|
(2,050,426 |
) |
Change in valuation allowance |
|
|
(12,858,776 |
) |
|
|
(4,996,208 |
) |
Income tax expense |
$ |
|
44,933 |
|
$ |
|
63,408 |
|
a.The statutory or “expected” tax rates are the U.K. rates of 25% for 2024 and 23.5% for 2023. The 2023 statutory rate represents that blended rate in effect for the year ended December 31, 2023 based on the 19.0% statutory rate that was in effect for the first quarter of 2023 and the 25.0% statutory rate that was in effect for the remainder of 2023. Amounts reflect adjustments (either a benefit or expense) to the “expected” tax expense for statutory rates in jurisdictions in which we operate outside of the UK.
|
The Company and its subsidiaries are liable to income taxes in their respective jurisdiction |
The Company and its subsidiaries are liable to income taxes in their respective jurisdiction. The Company has unused tax losses as follows as at December 31, 2024:
|
|
|
|
|
|
|
|
Tax loss carryforward |
|
|
Expiration date |
UK (1) |
$ |
|
41,980,917 |
|
|
(1) |
US |
|
|
6,238,596 |
|
|
Indefinite |
Spain |
|
|
1,106,475 |
|
|
Indefinite |
India |
|
— |
|
|
N/A |
Taiwan |
|
|
2,421,606 |
|
|
10 years |
|
Changes in our unrecognized tax benefits |
The changes in our unrecognized tax benefits for the indicated periods are summarized below:
|
|
|
|
|
|
|
|
|
|
2024 |
|
2023 |
|
Balance at January 1 |
$ |
|
33,754,069 |
|
$ |
|
24,388,433 |
|
Effect of rate changes: |
|
|
|
|
|
|
Additions based on tax positions related to current year |
|
|
10,719,324 |
|
|
|
6,882,336 |
|
Return to provision (based on tax return) |
|
|
16,505,726 |
|
|
— |
|
Tax losses lost on demerger |
|
|
(47,942,752 |
) |
|
— |
|
Foreign currency translation |
|
|
588,135 |
|
|
|
2,483,300 |
|
Balance at December 31 |
$ |
|
13,624,502 |
|
$ |
|
33,754,069 |
|
|
Significant portions of our deferred tax assets and liabilities |
The tax effects of temporary differences that give rise to the significant portions of our deferred tax assets and liabilities are presented below:
|
|
|
|
|
|
|
|
|
|
December 31, 2024 |
|
December 31, 2023 |
|
Deferred tax assets: |
|
|
|
|
|
|
Net operating loss and other carryforwards |
$ |
|
13,624,502 |
|
$ |
|
33,754,069 |
|
PP&E |
|
— |
|
|
— |
|
Derivative liabilities |
|
|
644,969 |
|
|
— |
|
Short-term debt to related party |
|
— |
|
|
|
1,556,454 |
|
Share-based payment liability |
|
|
350,000 |
|
|
|
327,757 |
|
Convertible debt |
|
|
7,382,329 |
|
|
|
8,110,222 |
|
Deferred tax assets |
|
|
22,001,800 |
|
|
|
43,748,501 |
|
Deferred tax liabilities: |
|
|
|
|
|
|
Derivative asset |
|
|
(646,895 |
) |
|
— |
|
Intangible assets |
|
|
(485,477 |
) |
|
— |
|
Deferred tax liabilities |
|
|
(1,132,372 |
) |
|
— |
|
Net Deferred tax asset |
|
|
20,869,428 |
|
|
— |
|
Valuation allowance |
|
|
(20,869,428 |
) |
|
— |
|
Net Deferred tax asset, net of valuation allowance |
$ |
|
— |
|
$ |
|
— |
|
|