As of 31 December, 2020, the Group also had € 2 844 million (2019: € 2 792 million) of gross unused tax losses and innovation income deduction for which no deferred tax asset is recognized in the statement of financial position . These tax attributes do not expire.
Based on current forecasts and current legislation, the majority of these tax attributes is expected to be fully utilized within the next 10 years, but it has been decided to not recognize a deferred tax asset on these losses for now given the uncertainty of such long-term forecasts.
32.3 Temporary differences for which no deferred tax asset or deferred tax liability is recognized
Deferred tax assets are recognized on temporary differences carried forward that represent income likely to be realized in the foreseeable future. Deferred tax assets amounting to gross € 312 million/net €78 million (2019: gross € 360 million/net 90 million) in respect of dividend received deduction and intangible assets have not been recognized in view of the uncertain character of the recovery.
No deferred tax liabilities are recognized for taxable temporary differences arising on investments in subsidiaries as 100% participation exemption is available for any future equity upstream.
There is an additional unrecognized deferred tax liability of € 115 million (2019: € 176 million) in respect of an internal reorganization which occurred in 2014. The tax liability will only materialize on disposal of the relevant asset, an event which is controlled by UCB and for which there are no concrete plans in the foreseeable future.