INCOME TAXES (Tables)
|
12 Months Ended |
Dec. 31, 2024 |
|---|
| INCOME TAXES |
|
| Schedule of Reconciliation of Income and Social Contribution Tax Expenses |
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. |
|
| Summary of Deferred Income Tax Assets and Liabilities |
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 |
|
|
| Schedule of estimate of tax credit realization |
|
|
Consolidated |
|
|
Within 1 year |
1,149,570 |
|
|
1 to 2 years |
670,316 |
|
|
2 to 3 years |
297,644 |
|
|
3 to 4 years |
423,267 |
|
|
4 to 5 years |
330,416 |
|
|
5 to 8 years |
1,248,040 |
|
|
8 to 10 years |
376,043 |
|
|
|
4,495,296 |
|
|
| Summary of Changes in Deferred Tax |
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 |
|