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INCOME AND SOCIAL CONTRIBUTION TAXES (Tables) | 6 Months Ended
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Jun. 30, 2021
INCOME AND SOCIAL CONTRIBUTION TAXES |
Schedule of deferred income and social contribution taxes | ​
​ | ​ | ​ | ​ | ​
​ | ​ | June 30, | ​ | December 31,
​ |  | 2021 |  | 2020
Tax loss | ​ | 1,136,946 | ​ | 1,013,008
Negative tax basis of social contribution | ​ | 393,958 | ​ | 329,412
​ | ​ | ​ | ​ | ​
Assets temporary differences | ​ | ​ | ​ | ​
Provision for judicial liabilities | ​ | 249,144 | ​ | 233,100
Operating provisions and other losses | ​ | 999,305 | ​ | 1,051,096
Exchange rate variation | ​ | 4,959,110 | ​ | 6,112,906
Derivatives losses ("MtM") | ​ | 1,394,959 | ​ | 2,303,833
Amortization of fair value adjustment on business combination | ​ | 710,737 | ​ | 718,645
Unrealized profit on inventories | ​ | 227,369 | ​ | 176,847
Lease | ​ | 269,452 | ​ | 287,066
Provision of deferred taxes on results of associates abroad | ​ | ​ | ​ | 33,893
Other temporary differences (1) | ​ | ​ | ​ | 158,172
​ | ​ | 10,340,980 | ​ | 12,417,978
​ | ​ | ​ | ​ | ​
Liabilities temporary differences | ​ | ​ | ​ | ​
Goodwill - Tax benefit on unamortized goodwill | ​ | 608,182 | ​ | 469,875
Property, plant and equipment - deemed cost | ​ | 1,366,017 | ​ | 1,385,642
Accelerated tax depreciation | ​ | 984,373 | ​ | 1,025,136
Borrowing cost | ​ | 98,934 | ​ | 110,036
Fair value of biological assets | ​ | 382,020 | ​ | 237,879
Tax provision on results of associates abroad | ​ | 53,744 | ​ | ​
Deferred taxes, net of fair value adjustment | ​ | 453,533 | ​ | 469,419
Tax credits - gains in tax lawsuit (exclusion of ICMS from the PIS and COFINS contribution tax basis) | ​ | 155,035 | ​ | 43,559
Other temporary differences | ​ | 14,526 | ​ | ​
​ | ​ | 4,116,364 | ​ | 3,741,546
​ | ​ | ​ | ​ | ​
Non-current assets | ​ | 6,224,616 | ​ | 8,677,002
Non-current liabilities | ​ | ​ | ​ | 570
​
1) | On December 29, 2020, with the final decision of Administrative Council for Economic Defense's ("CADE") approval, related to the purchase and sale agreement of rural property, Management and legal advisors understand that all conditions suspensive were implemented, with the tax recognition of capital gain being required, pursuant to art. 117 of the National Taxation Code ("CTN"). As the accounting recognition only occured at the Closing of the transaction, on January 5, 2021 (Note 1.2.2) with the fulfillment of the performance obligation and delivery of the ownership of the properties to the client, there was a need to establish the deferred tax asset on this difference temporary, in the amount of R$175,202.
​
Schedule of accumulated tax losses and social contribution tax loss carryforwards | ​
​ | ​ | ​ | ​ | ​
​ | ​ | June 30, | ​ | December 31,
​ |  | 2021 |  | 2020
Tax loss carry forward | ​ | 4,547,785 | ​ | 4,052,013
Negative tax basis of social contribution carryforward | ​ | 4,377,311 | ​ | 3,660,133
Schedule of changes in net balance of deferred income tax | ​
​ | ​ | ​ | ​ | ​
​ | ​ | June 30, | ​ | December 31,
​ |  | 2021 |  | 2020
Beginning balance | ​ | 8,676,432 | ​ | 1,555,165
Tax loss | ​ | 123,938 | ​ | 412,759
Negative tax basis of social contribution | ​ | 64,546 | ​ | 183,066
(Reversal) provision for judicial liabilities | ​ | 16,044 | ​ | (32,471)
Operating provision (reversal) and other losses | ​ | (19,292) | ​ | 136,400
Exchange rate variation | ​ | (1,153,796) | ​ | 4,110,964
Derivative losses (“MtM”) | ​ | (908,874) | ​ | 1,685,406
Amortization of fair value adjustment on business combination | ​ | 7,978 | ​ | 37,917
Unrealized profit on inventories | ​ | 50,522 | ​ | (116,475)
Lease | ​ | (17,614) | ​ | 265,022
Goodwill - Tax benefit on unamortized goodwill | ​ | (138,307) | ​ | (253,018)
Property, plant and equipment - deemed cost | ​ | 19,625 | ​ | 120,578
Accelerated tax depreciation | ​ | 40,763 | ​ | 88,064
Borrowing cost | ​ | 11,102 | ​ | (5,487)
Fair value of biological assets | ​ | (176,640) | ​ | (184,377)
Deferred taxes on the result of associates abroad | ​ | (87,637) | ​ | 497,743
Tax credits - gains in tax lawsuit (ICMS from the PIS/COFINS calculation basis) (Note 20.3) | ​ | (111,476) | ​ | ​
Other temporary differences (1) | ​ | (172,698) | ​ | 175,176
Ending balance | ​ | 6,224,616 | ​ | 8,676,432
​
1) | On December 29, 2020, with the final decision of CADE's approval related to the purchase and sale agreement of rural property (Note 1.2.2), Management and legal advisors understand that all conditions suspensive were implemented, with the tax recognition of capital gain being required, pursuant to art. 117 of the National Taxation Code ("CTN"). As the accounting recognition occurred at the Closing of the Transaction, on January 5, 2021 (Note 1.2.2) with the fulfillment of the performance obligation and delivery of the ownership of the properties to the client, there was a need to establish the deferred tax asset on this difference temporary, in the amount of R$175,202.
Schedule of changes in the effects of income tax and social contribution on profit or loss | ​
​ | ​ | ​ | ​ | ​ | ​
​ | ​ | June 30, | ​ | June 30, | ​
​ |  | 2021 |  | 2020 | ​
Net income (loss) before taxes | ​ | 9,888,881 | ​ | (24,236,648) | ​
Income tax and social contribution benefit (expense) at statutory nominal rate of 34% | ​ | (3,362,220) | ​ | 8,240,460 | ​
​ | ​ | ​ | ​ | ​ | ​
Tax effect on permanent differences | ​ | ​ | ​ | ​ | ​
Taxation (difference) on profit of associates in Brazil and abroad (1) | ​ | 1,162,607 | ​ | 746,640 | ​
Equity method | ​ | 30,724 | ​ | (1,004) | ​
Thin capitalization (2) | ​ | (364,176) | ​ | (252,808) | ​
Credit related to Reintegra Program | ​ | 3,615 | ​ | 3,367 | ​
Tax incentives applicable to income tax (3) | ​ | 3,886 | ​ | 3,925 | ​
Director bonus | ​ | (14,096) | ​ | (5,508) | ​
Write-off of tax credits, donations, fines and other | ​ | (67,781) | ​ | 29,997 | ​
​ | ​ | (2,607,441) | ​ | 8,765,069 | ​
Income tax | ​ | ​ | ​ | ​ | ​
Current | ​ | (148,847) | ​ | (57,006) | ​
Deferred | ​ | (1,806,012) | ​ | 6,486,044 | ​
​ | ​ | (1,954,859) | ​ | 6,429,038 | ​
Social Contribution | ​ | ​ | ​ | ​ | ​
Current | ​ | (6,816) | ​ | (823) | ​
Deferred | ​ | (645,766) | ​ | 2,336,854 | ​
​ | ​ | (652,582) | ​ | 2,336,031 | ​
Income and social contribution benefits (expenses) on the period | ​ | (2,607,441) | ​ | 8,765,069 | ​
​ | ​ | ​ | ​ | ​ | ​
Effective rate of income and social contribution tax expenses | ​ | 26.37% | ​ | 36.16% | ​
​
1) | The effect of the difference in taxation of associates is substantially due to the difference between the nominal rates of Brazil and associates abroad.
2) | The brazilian thin capitalization rules establish that interest paid or credited by a brazilian entity to a related party abroad may only be deducted for income tax and social contribution purposes if the interest expense is viewed as necessary for the activities of the local entity and when determined limits and requirements are met. On June 30, 2021 the Company did not meet all limits and requirements.
3) | Tax incentives applicable to ICMS, which is deducted from the calculation basis of Income Tax and Social Contribution.

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