PROVISION FOR LEGAL PROCEEDINGS AND JUDICIAL DEPOSITS (Tables)
|
12 Months Ended |
Dec. 31, 2024 |
PROVISION FOR LEGAL PROCEEDINGS AND JUDICIAL DEPOSITS |
|
Summary of Contingent Liabilities |
The Corporation had contingent liabilities and judicial deposits pertaining to:
|
|
Provision for lawsuits |
|
|
|
12/31/2024 |
|
|
12/31/2023 |
|
Tax |
|
745,896 |
|
|
813,732 |
|
Civil, environmental and regulatory |
|
818,422 |
|
|
512,979 |
|
Labor |
|
480,315 |
|
|
387,692 |
|
|
|
2,044,633 |
|
|
1,714,403 |
|
|
|
Judicial deposit |
|
|
|
12/31/2024 |
|
|
12/31/2023 |
|
Tax(i) |
|
801,723 |
|
|
652,236 |
|
Civil, environmental and regulatory |
|
134,058 |
|
|
114,724 |
|
Labor |
|
120,909 |
|
|
128,941 |
|
|
|
1,056,690 |
|
|
895,901 |
|
(i) |
In the year ended December 31, 2024, the Company, through its indirect subsidiary Comgás, made judicial deposits in the amount of R$110,170 in a lawsuit with a prognosis of possible loss to discuss the deductibility, from the IRPJ and CSLL calculation basis, of late payment interest on tax debts. |
|
Summary Changes in Provision for Legal Procedings |
Changes in provisions for lawsuits:
|
Tax |
|
|
Civil, environmental, and regulatory |
|
|
Labor |
|
|
Total |
|
Balance as of January 1, 2023 |
747,647 |
|
|
662,052 |
|
|
391,487 |
|
|
1,801,186 |
|
Provisioned in the year |
44,812 |
|
|
105,526 |
|
|
113,151 |
|
|
263,489 |
|
Write-offs by reversal / payment |
(33,427 |
) |
|
(258,021 |
) |
|
(168,160 |
) |
|
(459,608 |
) |
Transfer |
— |
|
|
3,793 |
|
|
607 |
|
|
4,400 |
|
Interest (i) |
54,700 |
|
|
(371 |
) |
|
50,607 |
|
|
104,936 |
|
Balance as of December 31,2023 |
813,732 |
|
|
512,979 |
|
|
387,692 |
|
|
1,714,403 |
|
Provisioned in the year |
129,619 |
|
|
181,734 |
|
|
154,193 |
|
|
465,546 |
|
Write-offs by reversal / payment |
(138,562 |
) |
|
(187,735 |
) |
|
(168,112 |
) |
|
(494,409 |
) |
Business combination |
1,382 |
|
|
91,913 |
|
|
4,831 |
|
|
98,126 |
|
Interest (i) |
(60,275 |
) |
|
219,531 |
|
|
101,711 |
|
|
260,967 |
|
Balance as of December 31, 2024 |
745,896 |
|
|
818,422 |
|
|
480,315 |
|
|
2,044,633 |
|
|
(i) |
In Includes write-off of interest due to reversal. |
|
Summary of Principal Tax Proceedings for Which Risk of Loss is Probable |
|
|
12/31/2024 |
|
|
12/31/2023 |
|
Compensation with FINSOCIAL (i) |
|
337,351 |
|
|
326,220 |
|
INSS (ii) |
|
101,399 |
|
|
100,149 |
|
ICMS credit (iii) |
|
64,708 |
|
|
174,860 |
|
PIS and COFINS |
|
34,412 |
|
|
33,244 |
|
IPI |
|
64,969 |
|
|
63,358 |
|
IRPJ and CSLL |
|
12,532 |
|
|
10,698 |
|
Other |
|
130,525 |
|
|
105,203 |
|
|
|
745,896 |
|
|
813,732 |
|
|
(i) |
Compensation of FINSOCIAL with federal taxes, based on a September 2003 final and non-appealable court ruling in the case records where the constitutionality of FINSOCIAL was discussed. Compensation of taxes remains a topic of administrative discussion. |
|
(ii) |
Amount provisioned as INSS, the majority of which is comprised of amounts related to social security contributions levied on billing in accordance with article 22-A of Law 8.212/91, the constitutionality of which is being litigated. The amounts are deposited with the court. The leading case, RE 611.601 (item 281), is being decided by the Federal Supreme Court, recognizing the constitutionality of art. 22-A of Law No. 8.212/91. |
|
(iii) |
ICMS: Tax assessments issued by the tax authorities relating to various types of ICMS credits, including: (a) assessment, as sole debtor, for alleged non-compliance with ICMS withholding obligations in relation to a toll contract arising from an agricultural partnership between our sugarcane mills and Central Paulista Ltda. Açúcar e Álcool; (b) ICMS relating to interstate operations taxed as domestic operations and therefore subject to a higher rate, among others. |
|
Summary of Principal Proceedings for Which Deem Risk of Loss as Possible |
|
|
12/31/2024 |
|
|
12/31/2023 |
|
Labor claims |
|
690,535 |
|
|
805,222 |
|
|
|
690,535 |
|
|
805,222 |
|
|