23. Taxes

The Group’s income tax has been calculated on the estimated taxable profit for each year at the rates prevailing in the respective tax jurisdictions. The subsidiaries of the Group in the jurisdictions where the Group operates are required to calculate their income taxes on a separate basis; thus, they are not permitted to compensate subsidiaries’ losses against subsidiaries income.

Income tax filing

IRSA Propiedades Comerciales S.A., in fiscal year 2021 (which was merged into IRSA Inversiones y Representaciones S.A.), and IRSA Inversiones y Representaciones S.A., in fiscal years 2022, 2023, 2024 and 2025, filed their income tax returns with the Argentine Tax Authorities applying the systemic and comprehensive inflation adjustment mechanism, as detailed below:

Together with the aforementioned tax returns, IRSA filed a multi-note form informing the application of such mechanisms, arguing that the effective tax rate would represent a percentage exceeding reasonable limits of taxation, thereby giving rise to a confiscatory situation in violation of Article 17 of the Argentine National Constitution (pursuant to the doctrine of the ruling “Candy S.A. v. AFIP et al. on Writ of Amparo”, judgment dated July 3, 2009, Fallos 332:1571, and subsequent precedents).

As of the issuance date of these financial statements, there are judicial precedents consistent with the Company’s position: the Candy ruling and the Supreme Court of Justice ruling in the case “Telefónica de Argentina S.A. et al. v. EN – AFIP – DGI on Dirección General Impositiva.”

Under the same criterion applied in the tax returns filed in the years mentioned, the provision for income tax for fiscal year 2026 was recorded.

It should also be noted that the deferred tax computation for the current fiscal year includes the legal option provided in Article 195 of the Income Tax Law, exercised in fiscal year 2024, which allowed one-third of the inflation adjustment for tax purposes to be recognized in that fiscal year and the remaining two-thirds to be allocated in equal parts over the two immediately following fiscal years, provided that certain investment requirements in fixed assets were met in those two fiscal years. For fiscal years 2024, 2025 and 2026, the investment requirement mentioned in the law has been duly met.

The Group analyzes the recoverability of its deferred tax assets when there are events or changes in circumstances that imply a potential indication of revaluation or devaluation. The value in use is determined on the basis of projected tax cash flows.

The aforementioned cash flows are prepared based on estimates regarding the future behavior of certain variables that are sensitive in determining the recoverable value, among which are: (i) sales projections; (ii) expense projections; (iii) macroeconomic variables such as growth rates, inflation rates, exchange rates, among others.

The details of the Group’s income tax, are as follows:

The statutory taxes rates in the countries where the Group operates for all of the years presented are:

Below is a reconciliation between income tax expense and the tax calculated applying the current tax rate, applicable in the respective countries, to profit before taxes for years ended June 30, 2026, 2025 and 2024:

Deferred tax assets and liabilities of the Group as of June 30, 2026 and 2025 will be recovered as follows:

The movement in the deferred income tax assets and liabilities during the years ended June 30, 2026 and 2025, without taking into consideration the offsetting of balances within the same tax jurisdiction, is as follows:

(i) See Note 4 to these Consolidated Financial Statements

Deferred income tax assets are recognized for tax loss carry-forwards to the extent that the realization of the related tax benefits through future taxable profits is probable. Tax loss carry-forwards may have expiration dates or may be permanently available for use by the Group depending on the tax jurisdiction where the tax loss carry forward is generated. Tax loss carry forwards in Argentina and Uruguay expire within 5 years, while in Israel they do not expire. Tax loss carry forward in Bolivia expire within 3 years Tax loss carry forwards in Brazil do not expire. However, in Brazil, the taxable profit for each year can only be reduced by tax losses up to a maximum of 30%.

As of June 30, 2026, the Group's recognized tax loss carry forward prescribed as follows:

The Company assesses the recoverability of deferred tax assets by considering the likelihood that some or all of such assets may not be realized. In making this assessment, the Company’s management considers the scheduled reversal of deferred tax liabilities, its business projections and tax planning strategies.

On this basis, as of June 30, 2026, the Company considers it probable that all recognized deferred tax assets and tax credits will be realized.

As of June 30, 2025, the Group did not recognize deferred income tax assets related to tax loss carryforwards amounting to ARS 14,497. Although Management projected sufficient taxable profits for certain Group businesses once they became operational, in accordance with IAS 12, Management determined that the recent history of losses and the lack of verifiable objective evidence, due to the limited operating history of certain subsidiaries, resulted in sufficient uncertainty regarding the generation of future taxable profits that could be used to offset the losses incurred within a reasonable period. Accordingly, no deferred tax asset was recognized in connection with such losses.