Accounting policy

The total rate of income tax and social contribution is 34%. Current tax and deferred tax are recognized in profit or loss, with the exception of certain transactions which are directly recognized in shareholder’s equity or other comprehensive income.

a)Current tax

It is the expected tax payable or receivable on taxable profit or loss for the year, using tax rates enacted or substantively enacted as of the date of the financial position, as well as any adjustments to tax payable in respect of prior years.

b)Deferred tax

Deferred tax is recognized as temporary differences between the carrying amounts of assets and liabilities for financial reporting purposes and the amounts used for taxation and tax loss.

The measurement of deferred tax reflects how the Company expects, at the end of the reporting period, to realize or settle the carrying value of its assets and liabilities. Deferred tax is measured at the rates anticipated to be applied to temporary differences upon their reversal, using rates enacted or substantively enacted as of the date of the financial position.

If there is a legally enforceable right to offset current tax assets and liabilities, and if they relate to taxes imposed by the same tax authority on the same taxable entity, deferred tax assets and liabilities are offset.

c)Tax exposure

In calculating the amount of current and deferred tax, the Company considers the impact of uncertain tax positions and the possibility of additional taxes and interest being owed. This evaluation is based on estimates and hypotheses and may involve a series of future event judgments. New information may become available, causing the Company to change its opinion regarding the sufficiency of existing tax liabilities; such changes in tax obligations will have an impact on tax expenses in the period in which the determination is made.

d)Recoverability of deferred income tax and social contribution

When evaluating the recoverability of deferred taxes, Management takes future taxable income projections and changes in temporary differences into account. The recoverability of the deferred tax asset in the parent company depends on taxable income projections. When it is unlikely that a portion or all the tax liability will be realized, the tax asset is reversed. No deadline exists for the utilization of tax losses and negative bases, but the utilization of these accumulated losses from prior years is limited to 30% of annual taxable income.

The Company and its subsidiaries adhere to both the letter and spirit of the tax laws and regulations of the countries in which they conduct business, being committed to good tax practices. They are also committed to the practice of transfer pricing that respects the principles of full competition and the rules defined by the tax legislation of the jurisdictions in which they operate, with transparency of operations, business ethics, and no use of practices that result in an artificial reduction in taxation.

a) Reconciliation of income tax and social contribution expenses:

	12/31/2024		12/31/2023		12/31/2022
Profit before taxes	(5,245,119	)	5,113,751		2,652,625
Income tax and social contribution at nominal rate (34%)	1,783,340		(1,738,675	)	(901,893	)
Adjustments for calculating the effective rate
Interest in earnings of investees (non-taxable income)	(1,422,337	)	672,947		122,238
Differences in tax rates on earnings from operating profit	(93,121	)	(62,870	)	(16,973	)
Granted income tax incentive	407,231		279,941		197,307
Share-based payment transactions			—		(73	)
Interest on shareholders’ equity	(174,335	)	(191,763	)	(26,058	)
Goodwill amortization effect	1,271		1,271		—
Non-deductible expenses (donations, gifts, etc.)	(23,234	)	(16,787	)	(13,788	)
Tax losses not recorded	(4,193,767	)	(308,358	)	(228,579	)
ICMS benefit - extemporaneous tax credits	20,490		5,506		345,067
ICMS benefit - current year	(521	)	68,409		242,694
Dividend income	—		254,260		—
Provision for non-realization of the benefit of the federative covenant	885		(307,099	)	—
Provision for non-realization of the benefit of the federative covenant - Interest and Fine	25,851		100,731		—
Selic on indebtedness	60,873		147,741		22,103
Rate differential⁽ⁱ⁾	534,837		805,725		446,293
Amortization of the effects on formation of joint venture			—		—
Benefit Membership Program Zero Litigation	(415	)	23,276		—
Other	(117,570	)	(8,681	)	(69,934	)
Income tax and social contribution (current and deferred)	(3,190,522	)	(274,426	)	118,404
Effective rate - %	60.83%		(5.37%	)	(4.46%	)

(i)	Difference in rate between the nominal rate of 34% and the effective rate applicable to entities that calculate the tax under the presumed profit regime.

b)Deferred income tax assets and liabilities

Below are presented the tax effects of temporary differences that give rise to significant parts of the company's deferred tax assets and liabilities:

	Consolidated
	12/31/2024		12/31/2023
Deferred tax assets from:
Income taxes losses	1,699,262		2,714,996
Negative base of social contribution	560,110		929,055
Temporary differences
Foreign exchange variation - Loans and borrowings	2,669,489		1,292,954
Provision for lawsuits	272,886		218,881
Impairment provision (Rumo Malha Oeste)	23,436		27,072
Post-employment benefit obligation	128,046		150,336
Provisions for uncertain tax credits and tax losses	44,202		34,511
Provision for non- recoverability of taxes	70,719		73,641
Share-based payment transactions	103,454		157,825
Lease	312,402		161,840
Unrealized loss with derivatives	390,622		823,286
Provisions for profit sharing	131,254		159,994
Business combination - Intangible assets	124,628		124,379
Business combination – Property, plant and equipment	1,854		24,795
Other provisions	682,385		691,162
Deferred tax on pre-operating income	79,402		87,454
Regulatory asset (liability)	8,396		6,661
Other	321,966		391,444
Total	7,624,513		8,070,286
Deferred tax liabilities from:
Temporary differences
Exchange rate variation - Loans and borrowings	(347	)	(195,232	)
Provision for lawsuits	(107	)	(408	)
Useful life review	(531,081	)	(456,093	)
Business combination – fixed assets	(161,784	)	(148,872	)
Tax goodwill	(645,297	)	(618,758	)
Unrealized income with derivatives	(369,763	)	(299,965	)
Fair value adjustment on debt	(801,022	)	(281,784	)
Marketable securities	—		(77,437	)
Investment properties	(496,395	)	(455,773	)
Goods intended for sale	(962	)	(10,546	)
Effects on the formation of joint ventures	(167,196	)	(103,992	)
Business Combination – Intangible assets	(4,990,657	)	(4,426,881	)
Post-employment obligations	(4,810	)	(4,641	)
Lease	(11,557	)	(10,034	)
Provisions	(449,153	)	(449,153	)
Other	(472,592	)	(147,120	)
Total	(9,102,723	)	(7,686,689	)
Total deferred taxes recorded	(1,478,210	)	383,597
Deferred tax assets	4,495,296		5,609,030
Deferred tax liabilities	(5,973,506	)	(5,225,433	)
Total deferred, net	(1,478,210	)	383,597

c) Changes in deferred tax assets and liabilities:

Assets:

	Consolidated
	Tax loss and negative basis		Post-employment obligations		Employee benefits		Provisions	Leases		Unrealized gains on derivatives		Intangible assets	Other		Total
Balance as of January 1, 2023	3,054,210		152,373		207,313		922,526	167,962		674,554		119,060	2,345,479		7,643,477
Credited / charged from income for the year	589,841		(2,037	)	110,506		122,741	(6,122	)	148,732		5,319	(133,596)		835,384
Foreign exchange differences	—		—		—		—	—		—		—	(408,575	)	(408,575	)
Balance as of December 31, 2023	3,644,051		150,336		317,819		1,045,267	161,840		823,286		124,379	1,803,308		8,070,286
Credited / charged from income for the year	(1,343,586	)	(22,290	)	(83,111	)	5,398	4,990		(433,630	)	249	(98,736	)	(1,970,716	)
Recognized in shareholders' equity	—		—		—		—	145,572		966		—	—		146,538
Zero litigation	(41,093	)	—		—		—	—		—		—	—		(41,093	)
Foreign exchange differences	—		—		—		—	—		—		—	1,376,535		1,376,535
Business combination	—		—		—		42,963	—		—		—	—		42,963
Balance as of December 31, 2024	2,259,372		128,046		234,708		1,093,628	312,402		390,622		124,628	3,081,107		7,624,513

Liabilities:

	Consolidated
	Effects on the formation of joint ventures		Post-employment obligations		Intangible assets		Unrealized gains on derivatives		Property, plant and equipment		Fair value adjustment		Leases		Provisions		Other		Total
Balance as of January 1, 2023	(106,254	)	(4,594	)	(4,486,211	)	(226,243	)	(401,926	)	(548,726	)	(11,797	)	(79,092	)	(2,773,878	)	(8,638,721	)
Impact on the results for the year	2,262		(47	)	59,330		(73,722	)	(54,167	)	200,336		1,763		(370,469	)	1,178,542		943,828
Other comprehensive income	—		—		—		—		—		—		—		—		(58,402	)	(58,402	)
Liabilities available for sale	—		—		—		—		—		66,606		—		—		—		66,606
Balance as of December 31, 2023	(103,992	)	(4,641	)	(4,426,881	)	(299,965	)	(456,093	)	(281,784	)	(10,034	)	(449,561	)	(1,653,738	)	(7,686,689	)
Impact on the results for the year	(63,204	)	(169	)	126,999		(69,798	)	(74,988	)	(519,238	)	(1,523	)	301		(42,518	)	(644,138	)
Other comprehensive income	—		—		—		—		—		—		—		—		(45,513	)	(45,513	)
Business Combinations (i)	—		—		(690,775	)	—		—		—		—		—		(35,608	)	(726,383	)
Balance as of December 31, 2024	(167,196	)	(4,810	)	(4,990,657	)	(369,763	)	(531,081	)	(801,022	)	(11,557	)	(449,260	)	(1,777,377	)	(9,102,723	)
Total deferred taxes recognized																			(1,478,210	)

(i)	The respective amount presented differs from the amount shown in note 9.2, due to the write-off of deferred liabilities, now constituted in connection with an indirect stake in the subsidiary Compagas

d) Unrecognized tax losses and temporary differences and Provision for non-recoverability of tax losses for the year