Accounting policy:
Current income taxes: In Brazil it comprises
income tax (“IRPJ“) and social contribution on profit (“CSLL“), which are calculated monthly based on taxable
profit, after offsetting tax losses and negative social contribution base, limited to 30% of the taxable income, applying the rate of
15% plus an additional 10% for the IRPJ and 9% for the CSLL.
The results obtained from foreign subsidiaries are
subject to taxation by the countries where they are based, according to applicable rates and legislation. In Brazil, these results suffer
the effects of taxation on universal basis established by the Law No. 12,973 / 14. The Company analyzes the results of each subsidiary
for the application of its Income Tax legislation, in order to respect the treaties signed by Brazil and avoid double taxation.
Deferred income taxes: These
are recognized when there are tax credits and debits on tax losses and negative CSLL bases, as well as temporary differences between the
tax base and the accounting base. Deferred tax assets and liabilities are classified as non-current. When the company's internal studies
indicate that the future use of these credits over a 10-year horizon is not probable, the asset is derecognized (note 10.1).
Deferred tax assets and
liabilities are presented net if there is enforceable legal right to be offset, and if they are under the responsibility of the same tax
authority and under the same taxable entity.
Deferred tax
assets and liabilities must be measured at the rates applicable in the year in which the asset is realized or the liability is settled,
based on the tax rates that have been enacted or substantively enacted by the end of the reporting period.
In compliance
with the interpretation ICPC 22 / IFRIC 23, the Company analyzed relevant tax decisions of higher courts and whether they conflict in
any way with the positions adopted by the Company. Regarding the known uncertain tax positions, the Company reviewed the corresponding
legal opinions and jurisprudence and did not identify impacts to be recorded.
The Company periodically assesses the positions
taken in which there are uncertainties about the tax treatment adopted and sets up a provision when applicable. |