
	Six months	Six months
	ended	ended
	June	June
	2026	2025
		Revised (1)
US Dollar millions	Unaudited	Unaudited

Current taxation (1)
Current year (1)	941	430
Prior year over provision	(12)	(9)
	929	421

Deferred taxation
Current year	21	5
Change in estimate	1	—
Prior year under provision	—	1
Change in corporate tax rate (2)	4	—
	26	6
	955	427

(2)The change in the corporate tax rate is due to various concession agreements expiring at a future date resulting in tax rates changing from concession rate to

The Group is subject to examination by tax authorities in the respective jurisdictions of operation, which give rise to tax litigation and

disputes resulting in uncertain tax positions. The Group assesses these uncertain tax positions to determine if a provision is required by

applying the appropriate accounting requirements, benchmarking to similar recent outcomes and, in some cases, advice from independent

experts. The economic outflow from these uncertain tax matters within the Group have been assessed as remote except for those

Organisation for Economic Co-operation and Development (OECD) Pillar Two model rules

The Group is within the scope of the OECD Pillar Two model rules as the Pillar Two legislation was enacted on 11 July 2023 in the UK, the

jurisdiction in which the Group’s parent company is incorporated, and came into effect from 1 January 2024. The Group applies the

exception to recognising and disclosing information about deferred tax assets and liabilities related to Pillar Two income taxes, as provided

in the amendments to IAS 12 “Income Taxes” (IAS 12) issued in May 2023.

Under the Pillar Two legislation, the Group is liable to pay a top-up tax for the difference between its Pillar Two effective tax rate per

jurisdiction and the 15% minimum rate. The Group recognised an estimated current tax expense related to Pillar Two for 2026 of $nil