The Company’s Brazilian subsidiaries receive tax assessments from local, state and federal tax authorities in Brazil from time to time. Current open tax assessments as of March 31, 2026 are: | | | | | | | | | | | | | | | | | Assessment received | Type of assessment | Type of Tax | Tax period impacted | Estimated amount, including interest and penalties as of March 31, 2026 | | | Aug-20 | State sales tax credits, which the Treasury Office of the State of Goiás considers as improperly registered | ICMS | 2017-2019 | R$839.6 million (approximately $159.8) | | | Oct-20 | Federal excise taxes, which the Treasury Office of the Brazil’s Internal Revenue Service considers as improperly calculated | IPI | 2016-2017 | R$501.7 million (approximately $95.5) | | Nov-22 | IPI | 2018-2019 | R$509.0 million (approximately $96.9) (a) | | Mar-24 | IPI | 2020 | R$39.5 million (approximately $7.5) | | Nov-20 | State sales taxes, which the Treasury Office of the State of Minas Gerais considers as improperly calculated | ICMS | 2016-2019 | R$260.0 million (approximately $49.5) | | Jun-21 | State sales tax, which the Treasury Office of the State of Goiás considers as improperly calculated | ICMS | 2016-2020 | R$0.0 million (approximately $0.0) (b) |
| | | | | | | | (a) During the first quarter of the current fiscal year, the tax assessment was revised as the case progressed through the Brazilian judicial system. As part of this reassessment, previously applied penalties were excluded in accordance with applicable tax regulations. As a result, the total liability was reduced compared to the prior assessment in the previous fiscal year. | (b) During the first quarter of the current fiscal year, the administrative case was decided in Coty's favor and prevailed against the tax authorities' appeal. |
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