v3.25.1
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