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RECOVERABLE TAXES
12 Months Ended
Dec. 31, 2024
RECOVERABLE TAXES  
RECOVERABLE TAXES
9 RECOVERABLE TAXES
12/31/202412/31/2023
IRPJ/CSLL – prepayments and withheld taxes227,464 464,188 
PIS/COFINS – on acquisitions of property, plant and equipment (1)
187,126 93,866 
PIS/COFINS – operations789,667 699,717 
PIS/COFINS – exclusions from ICMS (2)
405,407 443,210 
ICMS – on acquisitions of property, plant and equipment (3)
471,825 432,793 
ICMS – operations (4)
1,654,162 1,470,949 
Reintegra program (5)
70,610 64,077 
Other taxes and contributions64,444 45,821 
Provision for loss on ICMS credits (6)
(1,581,961)(1,452,435)
2,288,744 2,262,186
Current 1,109,619 888,539 
Non-current 1,179,125 1,373,647 
(1)Social Integration Program (“PIS”) and Social Security Funding Contribution (“COFINS”): Credits whose realization is based on the years of depreciation of the corresponding asset.
(2)The Company and its subsidiaries filed lawsuits over the years seeking the exclusion of ICMS from the PIS and COFINS contribution tax basis, in relation to certain transactions during various periods from March 1992.
(3)Tax on Sales and Services (“ICMS”): Credits from the acquisition of property, plant and equipment are recovered on a straight-line basis over a four-year period, from the acquisition date, in accordance with the relevant regulation, the ICMS Control on Property, Plant and Equipment (“CIAP”).
(4)ICMS credits accrued due to the volume of exports and credit generated from product import transactions: Credits are concentrated in the States of Espírito Santo, Maranhão, Mato Grosso do Sul e São Paulo, where the Company realizes the credits through the sale of credits to third parties, after approval from the State Ministry of Finance of each State. Credits are also being realized through the consumption of consumer goods (tissue) transactions in the domestic market.
(5)Special Regime of Tax Refunds for Export Companies ("Reintegra"): Reintegra is a program that aims to refund the residual costs of taxes paid throughout the export chain to taxpayers, to make them more competitive in foreign markets.
(6)Related to provisions for ICMS credit balances that are not probable to be recovered.
9.1 Roll-forward of provision for loss
ICMS
12/31/202412/31/2023
Opening balance(1,452,435)(1,103,807)
Addition (1)
(316,741)(399,838)
Reversal (2)
186,014 51,210 
Write-off1,201  
Closing balance(1,581,961)(1,452,435)
(1)Refers, substantially, to the accumulated ICMS credits of the state of Mato Grosso do Sul, arising from the construction operations of the Cerrado Project, and of the state of Espirito Santo, of the accumulated credits due to the volume of exports.
(2)Refers mainly to the reversal of the provision for loss resulting from the recovery of ICMS credits from the State of Espírito Santo through sale to third parties.