For the Year Ended December 31,
		2025				2024				2023
Current tax (benefit) expense
Current income tax		$	2,703,389			$	3,924,599			$	3,025,179
Deferred income tax			(5,602,656	)			68,751,097				(55,155,403	)
		$	(2,899,267	)		$	72,675,696			$	(52,130,224	)

The Mexican Tax Law effective as of January 1, 2014 is applicable to the Company, which imposes an income tax rate of 30%.

The UK entities are subject to UK corporation tax with an applicable rate of 25%.

Amounts recognized in profit or loss

Management has determined that the recoverability of cumulative tax losses, which expire in 2028 - 2035, is not feasible based on estimated breakeven of hotel operations. Therefore, the Company has not recognized certain expected income tax losses in the determination of deferred income tax, except for those companies that have taxable profit to offset the income tax losses.

Amounts recognized in OCI

	As of December 31, 2025												As of December 31, 2024												As of December 31, 2023
	Before				Tax (expense)				Net of				Before				Tax (expense)				Net of				Before				Tax (expense)				Net of
	tax				benefit				tax				tax				benefit				tax				tax				benefit				tax
Items that will not be reclassified to profit and loss
Remeasurements of defined benefit liability		$	1,365,506			$	(409,652	)		$	955,854			$	16,372			$	(4,762	)		$	11,610			$	124,599			$	(37,380	)		$	87,219
Revaluation of property, construction in process and equipment			(3,783,944,143	)			1,135,183,243				(2,648,760,900	)			334,809,588				(100,442,876	)			234,366,712				(889,982,346	)			266,994,704				(622,987,642	)
		$	(3,782,578,637	)		$	1,134,773,591			$	(2,647,805,046	)		$	334,825,960			$	(100,447,638	)		$	234,378,322			$	(889,857,747	)		$	266,957,324			$	(622,900,423	)

Reconciliation of effective tax rate

		For the Year Ended December 31,
		2025				2024				2023
(Loss) profit before income tax		$	(285,279,802	)		$	(3,495,289,882	)		$	5,662,697
Tax using the Company´s domestic tax rate			30	%			30	%			30	%
Income tax at legal tax rate			(85,583,941	)			(1,048,586,965	)			1,698,809
Tax effect of:
Annual adjustment inflation			19,736,040				35,881,580				86,082,320
Non-deductible expenses			8,942,866				9,847,790				5,970,038
Mainly change in allowance for NOL’s and other permanent differences			54,005,768				1,075,533,291				(145,881,392	)
Total tax expense		$	(2,899,267	)		$	72,675,696			$	(52,130,224	)

Movement in deferred tax balances

2025		Net balance as of January 1,				Recognized in profit and loss				Recognized in OCI				Final balance
Prepayments		$	(12,868,926	)		$	10,986,160			$	-			$	(1,882,766	)
Property, plant and equipment			(95,323,604	)			26,808,092				-				(68,515,512	)
PP&E Surplus			(3,548,469,730	)			9,023,076				1,135,183,243				(2,404,263,411	)
PP&E (capitalized foreign exchange rate and interest expense)			(220,604,535	)			-				-				(220,604,535	)
Investment properties			(372,371,632	)			(22,500,000	)			-				(394,871,632	)
Right of use of assets			(60,049,712	)			15,193,798				-				(44,855,914	)
Derivatives			-				-				-				-
Accruals			23,045,513				31,312,320				-				54,357,833
Debt cost to be amortized			(69,902,187	)			2,554,827				-				(67,347,360	)
Advance customers			5,196,925				29,576,603				-				34,773,528
Lease liabilities			62,014,298				(13,364,025	)			-				48,650,273
Equipment rent			84,603,406				(84,603,406	)			-				-
Employees’ benefits			3,151,126				816,118				(409,652	)			3,557,592
Employees’ statutory profit sharing			780,459				(205,119	)			-				575,340
		$	(4,200,798,599	)		$	5,598,444			$	1,134,773,591			$	(3,060,426,564	)

2024		Net balance as of January 1,				Recognized in profit and loss				Recognized in OCI				Final balance
Prepayments		$	(3,999,701	)		$	(8,869,225	)		$	-			$	(12,868,926	)
Property, plant and equipment			(39,818,079	)			(55,505,525	)			-				(95,323,604	)
PP&E Surplus			(3,471,731,220	)			23,704,366				(100,442,876	)			(3,548,469,730	)
PP&E (capitalized foreign exchange rate and interest expense)			(231,042,798	)			10,438,263				-				(220,604,535	)
Investment properties			(300,519,080	)			(71,852,552	)			-				(372,371,632	)
Right of use of assets			(65,111,127	)			5,061,415				-				(60,049,712	)
Derivatives			(35,077,118	)			35,077,118				-				-
Accruals			3,370,885				19,674,628				-				23,045,513
Debt cost to be amortized			-				(69,902,187	)			-				(69,902,187	)
Advance customers			46,637,589				(41,440,664	)			-				5,196,925
Lease liabilities			62,388,460				(374,162	)			-				62,014,298
Equipment rent			-				84,603,406				-				84,603,406
Employees’ benefits			2,629,807				526,081				(4,762	)			3,151,126
Employees’ statutory profit sharing			672,518				107,941				-				780,459
		$	(4,031,599,864	)		$	(68,751,097	)		$	(100,447,638	)		$	(4,200,798,599	)

Unrecognized deferred tax assets

Deferred tax assets have not been recognized in respect of the following items, because it is not probable that future taxable profit will be available against which the Company can use the benefits therefrom.

		As of December 31, 2025								As of December 31, 2024
		Gross amount				Tax effect				Gross amount				Tax effect
Income tax losses		$	1,904,835,875			$	571,450,763			$	1,698,038,184			$	509,411,455
Interest to be deducted			256,196,287				76,858,886				408,193,235				122,457,971
Other assets			-				-				41,049,602				12,314,881
		$	2,161,032,162			$	648,309,649			$	2,147,281,021			$	644,184,307

Tax losses carried forward

Tax losses for which no deferred tax asset was recognized expire as follows:

		Gross				Expire
Year		amount				rate
2018		$	463,327,909				2028
2020			30,851,973				2030
2021			15,727,355				2031
2022			37,489,376				2032
2023			4,450,065				2033
2024			557,141,333				2034
2025			795,847,864				2035
Total income tax losses		$	1,904,835,875

The Company has NOLs in the trusts that only can be used by them up to the reverse of the NOLs in future periods. These NOLs can not be used by other entities within the Company.