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Income Tax

12 Months Ended

Dec. 31, 2024

18. INCOME TAX

The income tax expense contemplates the application of the integral inflation adjustment mechanism applicable to property, plant and equipment, and the indexation of the accumulated tax losses carryforward until the concurrence of the tax result of the fiscal year 2024, all considering that the assumption of confiscation is verified, in the Company’s opinion, in accordance with the jurisprudence of the CSJN in force as of the date of issuance of these consolidated financial statements.

The Company, based on the opinion of its external advisors, considers that the position adopted is in line with the criteria, in accordance with the jurisprudence of the CSJN and a possible controversy with the tax authorities in the ultimate applicable legal instance would have a final and definitive resolution favorable to the Company, in accordance with the guidelines of IFRIC 23 (see Note 2.c) “Income tax and deferred taxes” section). For the year ended December 31, 2024, the assumed tax criteria generated a profit of 981.

The calculation of the income tax expense accrued for the years ended December 31, 2024, 2023 and 2022 is as follows:


	2024		2023		2022
Current income tax		(137)		(45)	(31)
Deferred income tax		1,349		(975)	(810)

		1,212		(1,020)	(841)

Income tax - Well abandonment		-		-	19	(1)

		1,212		(1,020)	(822)

(1)	Corresponding to the effect of the regularization regime for the dispute relating to the cost deduction for hydrocarbon wells abandonment. See Note 17.a.5).

The reconciliation between the income tax charge for the years ended December 31, 2024, 2023 and 2022 and the one that would result from applying the prevailing tax rate on net profit or loss before income tax arising from the consolidated statements of comprehensive income for each fiscal year is as follows:


	2024		2023			2022
Net profit / (loss) before income tax		1,181		(257)			3,056
Average tax rate (1)		25.32%		25.29%			25.33%

Average tax rate applied to net profit or loss before income tax		(299)		65			(774)
Effect of the valuation of property, plant and equipment, intangible assets and assets held for sale, net		1,966		(1,193)			154
Effect of exchange differences and other results relating to the valuation of the currency, net (2)		(1,836)		990			(112)
Effect of the valuation of inventories		(137)		(549)			(268)
Income on investments in associates and joint ventures		99		24			112
Effect of tax rate change (3)		452		(423)			(25)
Effect of the regularization regime for the dispute relating to the cost deduction for hydrocarbon wells abandonment		-		-			18	(4)
Effect of application of indexation mechanisms		981		-			-
Miscellaneous		(14)		66	(5)		73

Income tax		1,212		(1,020)			(822)

(1)	Corresponds to the average projected tax rate of YPF and its subsidiaries in compliance with amendment to Law No. 27,630. See Note 36.f.1).

(2)	Includes the effect of tax inflation adjustments.

(3)	Corresponds to the remediation of deferred income tax balances at the time of reversal. See Note 36.f.1).

(4)	See Note 17.a.5).

(5)	Includes 32 corresponding to the tax criteria adopted in the 2023 tax return for fiscal year 2022 of the subsidiary Metrogas.

Furthermore, breakdown of Income tax liability, Deferred income tax assets, net and Deferred income tax liabilities, net deferred as of December 31, 2024, 2023 and 2022 is as follows:


	2024						2023						2022
	Non-current			Current			Non-current			Current			Non-current			Current
Income tax liability		2	(2)		126	(1)		4	(2)		31	(1)		26	(2)		27	(1)

(1)

Includes 1, 1 and 6 corresponding to the 12 installments of the regularization regimes associated with the dispute relating to the cost deduction for hydrocarbon well abandonment as of December 31, 2024, 2023 and 2022, respectively (see Note 17.a.5)). Additionally, includes the provision associated with the charge of current income tax net of unused tax credits and existing tax loss carryforwards.

(2)	Includes 2, 4 and 26 corresponding to the remaining installments of the regimes associated with the dispute relating to the cost deduction for hydrocarbon well abandonment as of December 31, 2024, 2023 and 2022, respectively (see Note 17.a.5)).


	2024		2023		2022
Deferred tax assets
Provisions and other non-deductible liabilities		202		113		154
Property, plant and equipment and Assets held for sale		524		-		-
Lease liabilities		258		234		188
Tax loss carryforwards		13		1,782		167
Miscellaneous		1		1		1

Total deferred tax assets		998		2,130		510

Deferred tax liabilities
Property, plant and equipment, Intangible assets and Inventories		(224)		(2,017)		(1,028)
Adjustment for tax inflation (1)		(271)		(1,078)		(965)
Right-of-use assets		(247)		(221)		(180)
Miscellaneous		(16)		(38)		(53)

Total deferred tax liabilities		(758)		(3,354)		(2,226)

Total Net deferred tax (2)		240		(1,224)		(1,716)

(1)	Includes the effect of the deferral of the tax inflation adjustment. See Note 36.f.1) “Budget Law 2023 - Deferral of tax adjustment for inflation” section.

(2)

Includes (61), (96) and (86) corresponding to adjustment for inflation of the opening deferred tax of subsidiaries with the peso as functional currency which was charged to “Other comprehensive income” in the statement of comprehensive income and includes 176, 1,563 and 965 corresponding to the effect of the translation, as of December 31, 2024, 2023 and 2022, respectively.

As of December 31, 2024, the Group has recognized deferred tax assets for tax loss carryforwards for 13 that can be offset with taxable profits until the year 2029, in accordance with current tax laws.

As of December 31, 2024, 2023 and 2022, there are no material deferred tax assets which are not recognized that may be recoverable in the future.

As of December 31, 2024, 2023 and 2022, the Group has classified as deferred tax assets 330, 18 and 17, respectively, and as deferred tax liabilities 90, 1,242 and 1,733, respectively, all of which arise from the net deferred tax balances of each of the separate companies included in these consolidated financial statements.

As of December 31, 2024, 2023 and 2022, the causes that generated charges within “Other comprehensive income” line item in the statement of comprehensive income did not generate temporary differences subject to income tax.

On March 28, 2019, the Company agreed to adhere to the tax revaluation regime established under Law No. 27,430 for the “Mines, Quarries, Forests and Similar Assets” category. This allows a higher deduction of the depreciation of income tax revalued assets and therefore will affect the recording of the deferred income tax.