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Taxes | 6 Months Ended
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Jun. 30, 2025
Taxes |
Taxes |
| 12. | Taxes
| 12.1. | Income taxes
Schedule of income taxes |  |  |  |  |  |
| Current assets | Current liabilities | Non-current liabilities
| 06.30.2025 | 12.31.2024 | 06.30.2025 | 12.31.2024 | 06.30.2025 | 12.31.2024
Taxes in Brazil |  |  |  |  |  |
Income taxes (1) | 634 | 405 | 35 | 698 | 384 | 330
Income taxes - Tax settlement programs | − | − | 58 | 49 | 207 | 200
| 634 | 405 | 93 | 747 | 591 | 530
Taxes abroad (1) | 1 | 6 | 563 | 653 | − | −
Total | 635 | 411 | 656 | 1,400 | 591 | 530
(1) It includes uncertain tax treatments (see note 12.1.1).
Reconciliation between statutory income tax rate and effective income tax rate The following table provides the reconciliation of Brazilian statutory tax rate to the Company’s effective rate on income before income taxes:
Schedule of statutory income tax rate and effective income tax rate |  |  |  |
| Jan-Jun/2025 | Jan-Jun/2024 | Apr-Jun/2025 | Apr-Jun/2024
Net income (loss) before income taxes | 15,517 | 6,600 | 6,411 | (352)
Nominal income taxes computed based on Brazilian statutory corporate tax rates (34%) | (5,275) | (2,243) | (2,179) | 120
Adjustments to arrive at the effective tax rate: |  |  |  |
Tax benefits from the deduction of interest on capital distributions | 465 | 508 | 465 | 508
Different jurisdictional tax rates for companies abroad | 464 | 527 | 229 | 240
Brazilian income taxes on income of companies incorporated outside Brazil (1) | (111) | (142) | (41) | (92)
Tax incentives | 95 | 9 | 66 | (22)
Effects of the global minimum tax | (109) | - | (56) | -
Internal transfer prices adjustments for operations between related parties abroad | (165) | - | (86) | -
Tax loss carryforwards (unrecognized tax losses) | 1 | 83 | - | 27
Enrollment in the tax settlement program | - | (155) | - | (155)
Post-employment benefits | (208) | (652) | (94) | (531)
Results of equity-accounted investments in Brazil and abroad | 43 | (132) | 15 | (97)
Non-incidence of income taxes on indexation (Selic interest rate) of undue paid taxes | 30 | 48 | 17 | 27
Others | 5 | 29 | 10 | 2
Income taxes | (4,765) | (2,120) | (1,654) | 27
Deferred income taxes | (2,341) | 1,405 | (1,126) | 1,070
Current income taxes | (2,424) | (3,525) | (528) | (1,043)
Effective tax rate of income taxes | 30.7% | 32.1% | 25.8% | 7.7%
(1) It relates to Brazilian income taxes on earnings of offshore investees, as established by Law No. 12,973/2014.
Deferred income taxes - non-current The changes in the deferred income taxes are presented as follows:
Schedule of changes in the deferred income taxes |  |
| Jan-Jun/2025 | Jan-Jun/2024
Opening balance | (548) | (9,945)
Recognized in the statement of income for the period | (2,341) | 1,405
Recognized in shareholders’ equity | (3,238) | 2,499
Translation adjustment | (446) | 1,066
Use of tax loss carryforwards | (43) | (1)
Others | 19 | (3)
Closing balance | (6,597) | (4,979)
The composition of deferred tax assets and liabilities is set out in the following table:
Schedule of composition of deferred tax assets and liabilities |  |  |
Nature | Realization basis | 06.30.2025 | 12.31.2024
PP&E - Exploration and decommissioning costs | Depreciation, amortization and write-offs of assets | (6,730) | (6,286)
PP&E - Impairment | Amortization, impairment reversals and write-offs of assets | 3,958 | 3,462
PP&E - Right-of-use assets | Depreciation, amortization and write-offs of assets | (12,567) | (8,518)
PP&E - depreciation methods and capitalized borrowing costs | Depreciation, amortization and write-offs of assets | (18,593) | (16,043)
Loans, trade and other receivables / payables and financing | Payments, receipts and considerations | (1,085) | 2,636
Leasings | Appropriation of the considerations | 13,536 | 10,829
Provision for decommissioning costs | Payments and use of provisions | 10,321 | 9,118
Provision for legal proceedings | Payments and use of provisions | 928 | 818
Tax loss carryforwards | Taxable income compensation | 995 | 976
Inventories | Sales, write-downs and losses | 491 | 424
Employee Benefits | Payments and use of provisions | 1,354 | 1,191
Others |  | 795 | 845
Total |  | (6,597) | (548)
Deferred tax assets |  | 1,005 | 922
Deferred tax liabilities |  | (7,602) | (1,470)
| 12.1.1. | Uncertain tax treatments on income taxes
As of June 30, 2025, the Company has US$ 833 (US$ 767 as of December 31, 2024) of uncertain tax treatments, provisioned in the statement of financial position, mainly related to the deduction of amounts paid in the basis of calculation of income taxes in Brazil, as well as to the incidence of Corporate Income Tax (CIT) on transactions abroad, related to judicial and administrative proceedings. In addition, the Company has US$ 5,673 of uncertain tax treatments (US$ 5,229 as of December 31, 2024), unprovisioned, in Brazil and abroad, on income taxes related to judicial and administrative proceedings. As of June 30, 2025, the Company has other positions that can be considered as uncertain tax treatments on income taxes amounting to US$ 5,420 (US$ 4,274 as of December 31, 2024), given the possibility of different interpretation by the tax authority. These uncertain tax treatments are supported by technical assessments and tax risk assessment methodology. Therefore, Petrobras believes that such positions are likely to be accepted by the tax authorities (including judicial courts). Thus, as of June 30, 2025, the total amount of uncertain tax treatments amounts to US$ 11,927 (US$ 10,270 as of December 31, 2024), for which Petrobras will continue to defend its position.
| 12.2. | Other taxes
Schedule of recovery reversal of net deferred tax assets and liabilities |  |  |  |  |  |  |  |
| Current assets | Non-current assets | Current liabilities | Non-current liabilities (1)
| 06.30.2025 | 12.31.2024 | 06.30.2025 | 12.31.2024 | 06.30.2025 | 12.31.2024 | 06.30.2025 | 12.31.2024
Taxes in Brazil |  |  |  |  |  |  |  |
Current / Non-current ICMS (VAT) | 567 | 461 | 684 | 599 | 1,209 | 916 | − | −
Current / Non-current PIS and COFINS (2) | 586 | 1,043 | 2,607 | 2,044 | 413 | 373 | 173 | 134
Claim to recover PIS and COFINS | − | − | 663 | 590 | − | − | − | −
Production taxes | − | − | − | − | 1,570 | 1,509 | 78 | 87
Withholding income taxes | − | − | − | − | 117 | 294 | − | −
Others | 49 | 45 | 390 | 344 | 232 | 169 | 91 | 80
Total in Brazil | 1,202 | 1,549 | 4,344 | 3,577 | 3,541 | 3,261 | 342 | 301
Taxes abroad | 5 | 6 | 38 | 24 | 12 | 23 | − | −
Total | 1,207 | 1,555 | 4,382 | 3,601 | 3,553 | 3,284 | 342 | 301
(1) Other non-current taxes are classified within other non-current liabilities in the statement of financial position.
(2) In January and February 2025, the Company used credits arising from the tax settlement program which the Company enrolled in June 2024, which ended legal disputes over relevant litigation related to the incidence of taxes on remittances abroad, to compensate tax debts.
| 12.3. | Enrollment in the tax settlement program
In June 2024, Petrobras enrolled in a tax settlement program proposed by the Brazilian National Treasury by means of the Transaction Notice PGFN-RFB 6/2024, closing relevant litigation related to the taxation of remittances abroad, arising from contracts relating to the chartering of vessels and rendering of services, settling debts under dispute (contingent liabilities) relating to the taxation of CIDE, PIS and COFINS, from 2008 to 2013. This program brought economic benefits, avoiding costs with judicial guarantees, and included a 65% discount on the debt under dispute in Brazilian reais. The payment of the tax settlement was completed in the second half of 2024, as disclosed in the consolidated financial statements as of December 31, 2024, note 17.3. The effects of enrollment in this program resulted in a US$ 2,085 expense in the second quarter of 2024, net of reimbursements to Petrobras made by partners in E&P consortia of the amounts corresponding to their respective interests, whose enrollments in this program were approved by June 30, 2024.
Schedule of effects tax transaction in the statement of income |
Other taxes | 790
Net finance income (expense) | 2,149
Income taxes | (854)
Total effect on the statement of income | 2,085

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