uniQure N.V. Income Taxes Disclosure
20. Income taxes
a. Income tax expense
Due to the uncertainty surrounding the realization of favorable tax attributes in future tax returns, a valuation allowance is recorded against the Company’s net deferred tax assets in the Netherlands, and a partial valuation allowance against the Company’s net deferred tax assets in France.
There are no significant unrecognized tax benefits as of December 31, 2025 and 2024.
For the years ended December 31, 2025, 2024 and 2023, loss before income tax expense consists of the following:
Years ended December 31, | |||||||||
| 2025 | | 2024 | | 2023 | ||||
(in thousands) | |||||||||
Domestic - Netherlands | $ | (174,507) | $ | (215,251) | $ | (282,530) | |||
Foreign - U.S. |
| (4,470) |
| (1,133) |
| (6,903) | |||
Foreign - Other | (14,363) | (20,743) | (17,124) | ||||||
Total | $ | (193,340) | $ | (237,127) | $ | (306,557) | |||
The income tax expense for the years ended December 31, 2025, 2024 and 2023, consists of the following:
Years ended December 31, | |||||||||
| 2025 | | 2024 | | 2023 | ||||
(in thousands) | |||||||||
Current tax expense | |||||||||
Domestic - Netherlands | $ | (3,907) | $ | — | $ | — | |||
Other | (136) | (145) | (110) | ||||||
Total current income tax expense | $ | (4,043) | $ | (145) | $ | (110) | |||
Deferred tax expense |
|
|
| ||||||
Domestic - Netherlands | $ | (466) | $ | — | $ | — | |||
Other | (1,122) | (2,284) | (1,811) | ||||||
Total deferred tax expense | (1,588) | (2,284) | (1,811) | ||||||
Total income tax expense | $ | (5,631) | $ | (2,429) | $ | (1,921) | |||
b. Income taxes paid
The income taxes paid during the years ended December 31, 2025, 2024 and 2023 were as follows:
Years ended December 31, | |||||||||
| 2025 | | 2024 | | 2023 | ||||
(in thousands) | |||||||||
Domestic - Netherlands | $ | 7,403 | $ | — | $ | — | |||
Foreign | 139 | 21 | 12 | ||||||
Total | $ | 7,542 | $ | 21 | $ | 12 | |||
Since 2023, the Company has been engaged with the Dutch tax authorities regarding the Dutch corporate income tax treatment of the $375.0 million upfront payment received in exchange for the rights to the lowest royalty tier on CSL Behring’s worldwide net sales of HEMGENIX. In September 2025, the Dutch tax authorities communicated their position that, for Dutch corporate income tax purposes, the upfront payment should be treated as taxable income in 2023. In response, the Company revised its Dutch corporate income tax filing position to reflect the upfront payment as taxable income in 2023 (net of directly attributable expenses), together with a revision of a previously filed tax position, which resulted in a taxable profit of EUR 12.9 million ($14.6 million) for 2023, instead of the previous taxable loss for that year.
During 2025, the Company made a provisional payment of EUR 6.4 million ($7.4 million) in respect of the revised 2023 filing position. Subsequently, in conjunction with finalizing its positions, the Company also amended its 2021 Dutch corporate income tax filing position, which reduced the Company’s estimated Dutch corporate income tax related to 2023 to EUR 3.3 million ($3.9 million).
c. Tax benefit recognized in other comprehensive loss related to defined benefit pension plan liability
The reconciliation of the amount of income tax (loss) / benefit related to the defined benefit pension plan liability recognized in other comprehensive loss for the years ended December 31, 2025, 2024 and 2023, is as follows:
Years ended December 31, | |||||||||
| 2025 | | 2024 | | 2023 | ||||
(in thousands) | |||||||||
Unrecognized gain / (loss) related to defined benefit pension plan liability | $ | 887 | $ | 384 | $ | (2,553) | |||
Deferred tax (expense) / benefit | (116) | (57) | 417 | ||||||
Unrecognized gain / (loss) related to defined benefit pension plan liability, net of tax | $ | 771 | $ | 327 | $ | (2,136) | |||
d. Tax rate reconciliation
The reconciliation of the amount of income tax expense that would result from applying the domestic Dutch statutory income tax rate to the Company’s reported amount of loss before income tax expense for the years ended December 31, 2025, 2024 and 2023, is as follows:
Years ended December 31, | ||||||||||||||||||
2025 | 2024 | 2023 | ||||||||||||||||
| Amount | | Percent | | Amount | | Percent | | Amount | | Percent | |||||||
(in thousands) | (in thousands) | (in thousands) | ||||||||||||||||
Domestic statutory tax rate - Netherlands | $ | 49,882 | 25.8% | $ | 61,179 | 25.8% | $ | 79,092 | 25.8% | |||||||||
Foreign tax effects (difference in tax rates between the Netherlands and foreign jurisdictions) | (160) | (0.1%) | (149) | (0.1%) | (124) | (0.0%) | ||||||||||||
Domestic | ||||||||||||||||||
Changes in valuation allowance | (42,095) | (21.8%) | (53,745) | (22.7%) | (64,319) | (21.0%) | ||||||||||||
Non-deductible items | ||||||||||||||||||
Fair value changes | (4,687) | (2.4%) | 471 | 0.2% | (4,132) | (1.3%) | ||||||||||||
Other | (1,705) | (0.9%) | (2,417) | (1.0%) | (4,442) | (1.4%) | ||||||||||||
Foreign | ||||||||||||||||||
Changes in valuation allowance | (3,518) | (1.8%) | (3,805) | (1.6%) | (2,685) | (0.9%) | ||||||||||||
Non-deductible items | ||||||||||||||||||
Share-based payment awards | (2,746) | (1.4%) | (3,083) | (1.3%) | (5,332) | (1.7%) | ||||||||||||
Other | 44 | 0.0% | (655) | (0.3%) | (119) | (0.0%) | ||||||||||||
Other adjustments | (646) | (0.3%) | (225) | (0.1%) | 140 | 0.0% | ||||||||||||
Total tax provision and effective tax rate | $ | (5,631) | (2.9%) | $ | (2,429) | (1.0%) | $ | (1,921) | (0.6%) | |||||||||
e. Significant components of deferred taxes
The tax effects of temporary differences and carryforwards that give rise to significant portions of deferred tax assets and deferred tax liabilities as of December 31, 2025 and 2024 are as follows:
| Year ended December 31, | |||||
2025 | 2024 | |||||
(in thousands) | ||||||
Deferred tax assets: |
| |
| | ||
Net operating loss carryforwards | $ | 162,869 | $ | 178,421 | ||
Liability from royalty financing agreement | 123,042 | 19,476 | ||||
Intangibles | 1,866 | 4,702 | ||||
Operating lease liabilities | 3,588 | 3,846 | ||||
Accrued expenses and other current liabilities | 3,034 | 3,069 | ||||
Interest carryforwards | — | 2,956 | ||||
Property, plant and equipment |
| 1,007 |
| 365 | ||
Defined benefit pension plan liability | 207 | 260 | ||||
Total deferred tax assets | $ | 295,613 | $ | 213,095 | ||
Less valuation allowance |
| (271,429) |
| (191,864) | ||
Deferred tax assets, net of valuation allowance | $ | 24,184 | $ | 21,231 | ||
Acquired IPR&D intangible asset | (16,238) | (14,341) | ||||
Operating lease right-of-use assets | (3,564) | (3,864) | ||||
Other current assets and receivables | (3,308) | (48) | ||||
Property, plant and equipment | (387) | (165) | ||||
Deferred tax liability | $ | (23,497) | $ | (18,418) | ||
Net deferred tax asset | $ | 687 | $ | 2,813 | ||
Changes in the valuation allowance during the years ended December 31, 2025, 2024 and 2023 were as follows:
Years ended December 31, | |||||||||
| 2025 | | 2024 | | 2023 | ||||
(in thousands) | |||||||||
January 1, | $ | 191,864 | $ | 145,191 | $ | 74,547 | |||
Changes recorded in the statement of operations | 45,613 | 57,550 | 67,004 | ||||||
Changes recorded in equity | 6,525 | — | — | ||||||
Other changes including currency translation adjustments |
| 27,427 |
| (10,877) |
| 3,640 | |||
December 31, | $ | 271,429 | $ | 191,864 | $ | 145,191 | |||
The valuation allowance of $271.4 million as of December 31,2025 is primarily related to EUR 221.9 million ($260.7 million) of deferred tax assets in the Netherlands resulting from net operating loss carryforwards of EUR 118.4 million ($139.1 million), and a liability from the Royalty Financing Agreement of EUR 104.7 million ($123.0 million).
Netherlands
As of December 31, 2025, the total amount of net operating losses carried forward under the Dutch tax regime was EUR 458.9 million ($539.2 million), following the alignment of the Dutch corporate income tax treatment of the Royalty Financing Agreement in 2025, which consumed EUR 13.9 million ($15.7 million) of such net operating losses carried forward to 2025, and resulted in the recognition of a deferred tax asset related to the Liability from royalty financing agreement. As of December 31, 2024, the total amount of net operating losses carried forward was EUR 593.6 million ($616.5 million). The Company has historically recorded a full valuation allowance. The Company evaluates all positive and negative evidence in assessing the need for a full valuation allowance. Management considers reversing taxable temporary differences, projected future taxable income and tax-planning strategies in making this assessment. The Company concluded that as of December 31, 2025, and December 31, 2024 it is more likely than not that the remaining deferred tax assets will not be realized. The Company’s Dutch net operating tax losses carried forward relate to 2019, 2022, 2024 and 2025.
A portion of the valuation allowance for deferred tax assets recorded as of December 31, 2025 relates to follow-on offering costs incurred in 2019 and 2025. During the year ended December 31, 2025, the Company released $0.5 million of the valuation allowance related to 2019 and recorded a deferred tax expense as a result of adjusting the 2023 and 2021 Dutch corporate income tax filing positions. Any subsequently recognized tax benefits will be credited directly to Additional paid-in capital. As of December 31, 2025, that amount was EUR 8.4 million ($9.9 million) and EUR 3.0 million ($3.2 million) as of December 31, 2024.
The Dutch corporate tax rate is 25.8% from 2022 onwards.
Net operating loss carryforwards subject to a limit of offsetting taxable profit in excess of EUR 1.0 million to 50% of the taxable profit can be carried forward indefinitely.
The fiscal periods from 2021 onwards are still open for inspection by the Dutch tax authorities.
United States of America
The federal corporate tax rate in the U.S. is 21.0%. In addition, the Company is subject to state income taxes resulting in a combined tax rate of 27.3% for its U.S. operation. As of December 31, 2025, an estimated $20.1 million of net operating losses remain to be carried forward. These net operating losses carried forward will expire in 2036 and 2037 except for $0.7 million which may be carried forward indefinitely with a deduction limited to 80% of taxable income in a given year.
The Company’s U.S. operations have been generating taxable income since 2018 with the exception of 2022. The Company expects to continue to generate taxable income in the U.S. during the foreseeable future.
Under the provision of the Internal Revenue Code, the U.S. net operating losses carried forward may become subject to an annual limitation in the event of certain cumulative exchange in the ownership interest of significant shareholders over a three-year period, in excess of 50%, as defined under Section 382 and 383 of the Internal Revenue Code. This could limit the amount of tax attributes that can be utilized annually to offset future taxable income or tax liabilities. The amount of the annual limitation is determined based on the value of the Company immediately prior to the ownership change. Subsequent ownership changes may further affect the limitation.
The fiscal periods from 2022 are still open for inspection by the IRS. To the extent the Company has tax attribute carryforwards, the tax years in which the attribute was generated may still be adjusted upon examination by the IRS or Massachusetts Department of Revenue to the extent utilized in a future period. The Company is currently not under examination by the IRS for any tax years.
France
The French corporate tax rate for fiscal year 2025 was 25.0%. In addition, the Company is subject to a surcharge of 3.3% of the 25.0% standard corporate tax rate resulting in a combined rate of 25.8%.
The Company’s French operations have incurred losses since incorporation and are expected to continue incurring tax losses for the foreseeable future. The French operations as of December 31, 2025 have an estimated EUR 59.8 million ($70.3 million) of net operating losses EUR 48.9 million ($50.8 million) as of December 31, 2024) that are available for carry forward indefinitely. The Company recorded a partial valuation allowance during the years ended December 31, 2025, 2024, and 2023. The Company evaluates all positive and negative evidence including future income from reversing taxable temporary differences (particularly from reversing the deferred tax liability related to the acquired IPR&D intangible asset), projected future taxable income subject to the loss limitation rules applicable in France and tax-planning strategies in making this assessment.
Historical Timeline
| Fiscal Year | Filed | |
|---|---|---|
| 2025 | Mar 2, 2026 | Showing above |
| 2024 | Feb 27, 2025 | |
| 2023 | Feb 28, 2024 | |
| 2022 | Feb 27, 2023 | |
| 2021 | Feb 25, 2022 | |
| 2020 | Mar 1, 2021 | |
| 2019 | Mar 2, 2020 | |
| 2018 | Feb 28, 2019 | |
| 2017 | Mar 14, 2018 | |
| 2016 | Mar 15, 2017 | |
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.