35 Income tax payables
Income tax payables include liabilities for uncertain tax positions for an amount of € 91 million (2017: € 55 million). Liabilities for uncertain tax positions are recorded when the Group considers it probable that a tax position taken is unlikely to be sustained if challenged by the tax authorities. The assessment is done for all positions and is calculated taking into account the most likely outcome or the expected value, where appropriate. See Note 3.2.5 for more details on the Group’s assessment of uncertain tax positions.
UCB faces tax audits in a number of countries where activities are deployed. The issues under discussion are in some cases complex and such audits can take a number of years to resolve.
The liabilities for uncertain tax positions have increased over 2018. There has been a net increase in 2018 of liabilities resulting from remeasurement and roll-forward of existing tax risks, reversal of tax risks based on expiry of statutes of limitation and recognition of new liabilities all reflecting tax-technical merits of the case and state of discussions with tax authorities upon tax audit (where appropriate).
UCB has recorded assets for tax relief in a number of jurisdictions for an amount of € 17 million. Assets are only recorded in case it is considered probable that corresponding adjustments will be allowed following Mutual Agreement or Arbitration Procedure. See Note 3.2.5 for more details on the Group’s assessment of assets for tax audit corrections.
The Group strictly follows up on the liabilities for uncertain tax positions which are recorded per end 2018, also reflecting the status of the ongoing tax audits.