Income taxes
Net loss before income taxes is as follows (in thousands):
202520242023
United States$(74,158)$16,260 $11,612 
United Kingdom43,193 (74,429)(76,866)
Ireland
11,719 5,187 4,122 
Other worldwide146 45 242 
Net loss before income taxes$(19,100)$(52,937)$(60,890)
The components of income tax (expense) benefit are as follows (in thousands):
202520242023
Current:
United Kingdom$— $— 
United States - Federal and State(1,473)215 
Ireland
(1,624)(497)(436)
Other worldwide— (3)(19)
Total current tax (expense)
$(1,624)$(1,973)(240)
Deferred:
United Kingdom$— $— 
United States - Federal and State(14,790)3,823 5,873 
Ireland
— — (30)
Other worldwide— — 
Total deferred tax (expense) benefit
$(14,790)$3,823 $5,843 
Total income tax (expense) benefit
$(16,414)$1,850 $5,603 
The tax effects of temporary differences and carryforwards that give rise to deferred tax assets and liabilities were as follows (in thousands):
20252024
Deferred tax assets
Net losses$150,026 $69,350 
Fixed assets3,356 3,874 
R&D credits17,075 7,145 
Stock based compensation17,916 12,775 
Convertible senior notes
12,076 14,508 
Other deferred tax assets2,658 2,090 
Total deferred tax assets$203,107 $109,742 
Deferred tax liabilities
Other deferred tax liabilities(3,051)(2,788)
Total deferred tax liabilities$(3,051)$(2,788)
Valuation allowance(200,056)(92,164)
Net deferred tax assets$ $14,790 
The movements in the deferred tax asset valuation allowances are as follows (in thousands):
20252024
Valuation allowance as of January 1,$(92,164)$(83,126)
(Increase)/ decrease in valuation allowance through net loss
(100,675)(10,319)
Foreign currency translation adjustments(7,217)1,281 
Valuation allowance as of December 31,$(200,056)$(92,164)
Reconciliation of the U.K. statutory income tax rate, the income tax rate of the country of domicile of the Company, to the Company’s effective income tax rate is as follows (in percentages):
202520242023
U.K. statutory income tax rate$4,777 25.0 %$13,234 25.0 %$14,320 23.5 %
Foreign tax effects:
United States
Foreign rate differential
(2,966)(15.5)%6501.2 %2930.5 %
Share based payment3,04815.9 %2,1824.1 %3,2935.4 %
R&D expenditure credits2,09611.0 %1,2342.4 %1,4462.4 %
Change in valuation allowance
(40,513)(212.1)%4190.8 %3,5005.7 %
Return-to-provision adjustment7143.7 %2,1984.2 %2470.4 %
State taxes
4,39923.0 %(214)(0.4)%610.1 %
Other700.4 %(90)(0.2)%(50)(0.1)%
$(33,152)(173.6)%$6,379 12.1 %$8,790 14.4 %
Ireland
Foreign rate differential 1,4657.7 %6491.2 %4550.8 %
Return to provision adjustment
(253)(1.3)%— %— %
Other(47)(0.3)%1890.4 %490.1 %
$1,165 6.1 %$838 1.6 %$504 0.9 %
Other foreign jurisdictions— %7— %380.1 %
Non-taxable or Non-deductible Items
Share based payments(7,707)(40.3)%(5,682)(10.7)%(5,110)(8.4)%
R&D expenditure credits 1,653 8.7 %3,0645.8 %(3)— %
UK patent box50,288263.2 %— %— %
Convertible loan note deduction
2,445 12.8 %2,0673.9 %— %
Other
(179)(0.9)%(43)(0.1)%(567)(0.9)%
Change in valuation allowances(35,703)(186.9)%(18,014)(34.0)%(12,369)(20.3)%
Effective income tax rate$(16,414)(85.9)%$1,850 3.6 %$5,603 9.2 %
State taxes in Tennessee and Kentucky for the years ended December 31, 2025 and 2024, and Kentucky for the year ended December 31, 2023, represented more than 50 percent of the total tax effect within the United States jurisdiction category.
Income taxes paid (net of refunds) are disaggregated by jurisdiction as follows (in thousands):
202520242023
United Kingdom$— $— $— 
Foreign4,643 510 977 
$4,643 $510 $977 
Income taxes paid (net of refunds) exceeded 5 percent of total income taxes paid (net of refunds) in the following jurisdictions:
202520242023
United States$2,034 $169 $977 
Ireland2,548 341 — 
Other worldwide
61 — — 
$4,643 $510 $977 
As of December 31, 2025, the Company’s net operating loss carryforwards in the United Kingdom totaled $525.5 million and net operating loss carryforwards in the United States totaled $73.6 million.
As of December 31, 2025, the Company has U.S. R&D credit carryforwards totaling $10.3 million, of which, $9.5 million relates to federal tax credits.
U.K. tax credit carryforwards can be carried forward indefinitely to be offset against future tax liabilities of the company. Non-U.K. net operating loss carryforwards can be carried forward indefinitely. U.S. tax credit carryforwards can be carried forward for 20 years to be offset against future tax liabilities, subject to a minimum tax payment of 25% of the tax charge.
A valuation allowance is established when it is more likely than not that some portion or all of a deferred tax asset will not be realized. The realization of deferred tax assets depends on the generation of future taxable income during the period in which related temporary differences become deductible. The majority of the Company’s deferred tax assets relate to net operating loss and R&D carryforwards that can only be realized if the Company is profitable in future periods. Accordingly, the Company has provided a valuation allowance against a substantial amount of the net deferred tax assets due to uncertainties as to their ultimate realization.
The Company operates in multiple jurisdictions with complex tax and regulatory environment and the Company's tax returns are periodically audited or subjected to review by tax authorities. The following table summarizes tax years that remain subject to examination by tax jurisdiction as of December 31, 2025:
JurisdictionOpen Tax Years Based on Originally Filed Returns
United Kingdom
2023-2024
United States
2022-2024
Ireland
2021-2024
The Company accounts for uncertain tax positions in accordance with the provisions of ASC 740. When uncertain tax positions exist, the Company recognizes the tax benefit of tax positions to the extent that the benefit will more likely than not be realized. The determination as to whether the tax benefit will more likely than not be realized is based upon the technical merits of the tax position as well as consideration of the available facts and circumstances. As of December 31, 2025 and 2024, the Company has not recorded any provision for uncertain tax positions.

Historical Timeline

Fiscal YearFiled
2025Feb 25, 2026Showing above
2024Feb 26, 2025
2023Feb 28, 2024

About Income Taxes Disclosures

The income tax disclosure reveals how much a company actually pays in taxes versus what the statutory rate would predict. Analysts focus on the effective tax rate (ETR) reconciliation, which breaks down every item driving the gap between the 21% federal rate and the company's reported ETR — including R&D credits, foreign rate differentials, and state taxes. Deferred tax assets (DTAs) and their valuation allowances signal management's confidence in future profitability: a rising allowance suggests the company doubts it can use accumulated tax benefits. Uncertain tax benefit (UTB) reserves quantify exposure to IRS challenges on aggressive positions.

Key signals to watch: sudden ETR drops without clear operational reasons, large increases in valuation allowances, growing UTB balances, and significant unremitted foreign earnings. Post-TCJA, pay attention to GILTI and BEAT provisions that affect multinational tax structures. Compare the cash taxes paid (from the cash flow statement) against the income tax provision to gauge earnings quality.