v3.25.3
Income Taxes
 12 Months Ended
Sep. 27, 2025
Income Tax Disclosure [Abstract]  
Income Taxes Income Taxes
Income Before Income Taxes by Domestic and Foreign Subsidiaries
Income Before Income Taxes
202520242023
Domestic subsidiaries (including U.S. exports)$9,535  $5,754  $3,086  
Foreign subsidiaries
2,468  1,815  1,683  
$12,003  $7,569  $4,769  
Provision for Income Taxes: Current and Deferred
Income Tax Expense (Benefit)
Current202520242023
Federal$(130) $1,393  $1,475  
State413  237  402  
Foreign, including foreign withholding taxes
906  973  867  
1,189  2,603  2,744  
Deferred
Federal(2,171) (764) (1,180) 
State(527) 54  4  
Foreign81  (97) (189) 
(2,617) (807) (1,365) 
Income tax expense (benefit)
$(1,428) $1,796  $1,379  
Deferred Tax Assets and Liabilities
Components of Deferred Tax (Assets) and LiabilitiesSeptember 27, 2025September 28, 2024
Deferred tax assets
Net operating losses and tax credit carryforwards(1)
$(3,629) $(3,444) 
Accrued liabilities(1,011) (1,199) 
Licensing revenues
(807) (130) 
Lease liabilities(786) (862) 
Other(413) (655) 
Total deferred tax assets(6,646) (6,290) 
Deferred tax liabilities
Depreciable, amortizable and other property3,998  6,584  
Investment in U.S. entities
916  1,102  
Investment in foreign entities879  465  
Right-of-use lease assets
628  692  
Other89  78  
Total deferred tax liabilities6,510  8,921  
Net deferred tax (asset) liability before valuation allowance(2)
(136) 2,631  
Valuation allowance2,931  2,991  
Net deferred tax liability$2,795  $5,622  
(1)Further details on our net operating losses and tax credit carryforwards are as follows:
September 27, 2025
International Theme Park net operating losses
$(1,515) 
U.S. foreign tax credits(945) 
State net operating losses and tax credit carryforwards(701) 
Other(468) 
Total net operating losses and tax credit carryforwards(a)
$(3,629) 
(a)    Approximately $2.3 billion of these carryforwards do not expire and are primarily related to loss carryforwards at Disneyland Paris. Approximately $1.2 billion expire between fiscal 2026 and fiscal 2035 and are primarily related to U.S. foreign tax credits.
(2)In fiscal 2025, the Company completed the acquisition of NBCU’s interest in Hulu. At the close of the transaction, Hulu’s U.S. income tax classification changed, and the Company recognized a non-cash tax benefit of approximately $3.3 billion.
Valuation Allowance
The following table details the change in valuation allowance for fiscal 2025, 2024 and 2023 (in billions):
Balance at Beginning of Period
Increases (Decreases) to Tax Expense
Other ChangesBalance at End of Period
Year ended September 27, 2025
$3.0  $(0.1) $—  $2.9  
Year ended September 28, 2024
3.2  (0.3) 0.1  3.0  
Year ended September 30, 2023
2.9  0.2  0.1  3.2  
Reconciliation of the effective income tax rate for continuing operations to the federal rate
202520242023
Federal income tax rate21.0  % 21.0  % 21.0  % 
State taxes, net of federal benefit(1)
2.4 2.2 5.8 
Change in Hulu income tax classification
(27.3)— — 
Non-tax deductible impairments
0.9 8.8 3.5 
Foreign derived intangible income(2.2)(3.6)(4.3)
Income tax audits and reserves
(8.4)(2.4)1.3 
Tax rate differential on foreign income
3.4 (1.6)0.1 
U.S. research and development credits
(0.9)(1.1)(1.1)
Tax impact of equity awards
(0.3)0.8 2.1 
Valuation allowance(1.3)(0.6)(1.8)
Other0.8 0.2 2.3 
(11.9 %)23.7 %28.9 %
(1)Fiscal 2023 includes an adjustment related to certain deferred state taxes
Unrecognized tax benefits
A reconciliation of the beginning and ending amount of gross unrecognized tax benefits, excluding the related accrual for interest and penalties, is as follows:
202520242023
Balance at the beginning of the year$1,952  $2,517  $2,449  
Increases for current year tax positions105  82  98  
Increases for prior year tax positions116  209  273  
Decreases in prior year tax positions(164) (423) (144) 
Settlements with taxing authorities(256) (239) (153) 
Lapse in statute of limitations
(620) (194) (6) 
Balance at the end of the year$1,133  $1,952  $2,517  
Balances at September 27, 2025, September 28, 2024 and September 30, 2023 include $0.8 billion, $1.4 billion and $1.8 billion, respectively, that if recognized, would reduce our income tax expense and effective tax rate. These amounts are net of the offsetting benefits from other tax jurisdictions.
At September 27, 2025, September 28, 2024 and September 30, 2023 accrued interest and penalties related to unrecognized tax benefits were $0.3 billion, $0.9 billion and $1.0 billion, respectively. During fiscal 2025, 2024 and 2023, the Company recorded additional interest and penalties of $177 million, $157 million and $210 million, respectively, and recorded reductions in accrued interest and penalties of $816 million, $151 million and $241 million, respectively. The Company’s policy is to report interest and penalties as a component of income tax expense.
The Company is generally no longer subject to U.S. federal examination for years prior to 2018. The Company is no longer subject to examination in any of its major state or foreign tax jurisdictions for years prior to 2009.
In the next twelve months, it is reasonably possible that our unrecognized tax benefits could change due to the resolution of open tax matters, which would reduce our unrecognized tax benefits by $0.4 billion.
Other
In fiscal 2025, the Company recognized income tax benefits of $35 million for the excess of equity-based compensation deductions over amounts recorded based on the grant date fair value. In fiscal 2024 and 2023, the Company recognized income tax expense of $55 million and $93 million, respectively, for the shortfall between equity-based compensation deductions and amounts recorded based on the grant date fair value.
U.S. Legislation
In July 2025, legislation known as “One Big Beautiful Bill Act” was signed into law. The most significant tax impact on the Company will be cash timing benefits from acceleration of tax deductions on U.S. investments in fixed assets and content production, which will result in lower tax payments in the year of investment than would have otherwise occurred under the previous legislation. The cash tax benefit will begin to be realized in fiscal 2026 as U.S. federal and California state income tax
payments otherwise due in fiscal 2025 have been deferred pursuant to relief related to the 2025 wildfires in California. We do not expect a material impact on the Company’s income tax expense.