Income taxes

6 Months Ended

Jun. 30, 2025

Disclosure of temporary difference, unused tax losses and unused tax credits [abstract]

12 INCOME AND SOCIAL CONTRIBUTION TAXES

The Company calculates income tax and social contribution taxes, current and deferred, based on the following rates: (i) 15% plus an additional 10% on taxable income in excess of R$240 for IRPJ; and (ii) 9% for CSLL, on the net income. Balances are recognized in the Company's income on an accrual basis.

Subsidiaries domiciled in Brazil have their taxes calculated and provisioned in accordance with the current legislation and their specific tax regime, including, in some cases, the presumed profit method. Subsidiaries domiciled abroad are subject to taxation in their respective jurisdictions, according to local regulations.

Deferred income and social contribution taxes are recognized at the net amounts in non-current assets or liabilities.

In Brazil, Law nº. 12,973/14 revoked article 74 of Provisional Measure nº. 2,158/01 and determines that the parcel of the adjustment of the value of the investment in subsidiaries, direct and indirect, domiciled abroad, equivalent to the profit earned by them before income tax, except for exchange rate variation, must be added in the determination of taxable income and the social contribution calculation basis of the controlling entity domiciled in Brazil, at each year ended.

The Company management believes in the validity of the provisions of international treaties entered by Brazil to avoid double taxation. In order to ensure its right to non-double taxation, the Company filed a lawsuit in April 2019, which aims to exempt the double taxation in Brazil, of profits earned by its subsidiary located in Austria, according to Law No. 12,973/14. Due to the preliminary injunction granted in favor of the Company in the aforementioned lawsuit, the Company decided not to add the profit from Suzano International Trading GmbH, located in Austria, when determining its taxable income and social contribution basis of the net profit of the Company for the six-month period ended June 30, 2025. There is no provision for tax related to the non-double taxation profits of such subsidiary in 2025. Disclosures about uncertain tax positions for income tax and social contribution (IFRIC 23) are presented in Note 20.2.

12.1 Deferred taxes

12.1.1 Deferred income and social contribution taxes


	06/30/2025	12/31/2024
Tax loss carried forward	675,524	796,831
Negative tax basis of social contribution carried forward	259,406	307,143

Assets - temporary differences
Provision for judicial liabilities	275,965	324,873
Operating provisions	471,607	515,779
Provisions for other losses	578,522	547,242
Employee benefit plans	250,926	245,331
Exchange rate variations	4,156,021	7,385,034
Derivatives losses (“MtM”)(1)	168,018	2,230,835
Amortization of fair value adjustments arising from business combinations	623,209	625,745
Unrealized profit on inventories	383,369	539,157
Leases (1)	508,900	606,944
	8,351,467	14,124,914

Liabilities - temporary differences
Goodwill - tax benefit on unamortized goodwill	1,734,003	1,589,887
Property, plant and equipment - deemed cost	1,017,118	1,066,883
Depreciation for tax-incentive reason (2)	701,015	733,640
Capitalized loan costs	936,754	947,482
Fair value of biological assets	1,109,512	1,317,095
Deferred taxes, net of fair value adjustments	327,491	342,141
Tax credits - gains from tax lawsuit (exclusion of ICMS from the PIS and COFINS basis)	123,372	137,928

Provision of deferred taxes on results of subsidiaries abroad	19,710
Other temporary differences	5,582	18,439
	5,974,557	6,153,495

Non-current assets	2,376,910	7,984,015
Non-current liabilities		12,596

(1)The Company presents a net balance of derivatives and leases, as gains and losses from deferred taxes are offset simultaneously. For the derivatives line, the passive temporary difference was R$1,742,527 and asset temporary difference of R$1,910,544 (passive temporary difference was R$1,321,614 and asset temporary difference of R$3,552,449 as of December 31, 2024). For the lease line, the passive temporary difference was R$1,756,012 and asset temporary difference was R$2,264,912 (passive temporary difference was R$1,763,847 and asset temporary difference was R$2,370,791 as of December 31, 2024).

(2)Tax depreciation is taken as a benefit only in the income tax calculation bases.

12.1.2 Breakdown of accumulated tax losses and social contribution tax losses carried forward


	06/30/2025	12/31/2024
Tax loss carried forward	2,702,096	3,187,324
Negative tax basis of social contribution carried forward	2,882,289	3,412,700

12.1.3 Roll-forward of deferred tax assets


	06/30/2025	12/31/2024
Opening balance	7,971,419	533,836
Tax loss carried forward	(121,307)	(413,137)
Negative tax basis of social contribution carried forward	(47,737)	(149,887)
Provision for judicial liabilities	(48,908)	715
Operating provisions and other losses	(7,297)	93,545
Exchange rate variation	(3,229,013)	5,000,881
Derivative (gains) losses (“MtM”)	(2,062,817)	2,908,925
Amortization of fair value adjustments arising from business combinations	12,114	193
Unrealized profit on inventories	(155,788)	387,579
Leases	(98,044)	250,834
Goodwill - tax benefit on unamortized goodwill	(144,116)	(288,233)
Property, plant and equipment - deemed cost	49,765	70,600
Depreciation accelerated for tax-incentive reason	32,625	66,217
Capitalized loan costs	10,728	(307,419)
Fair value of biological assets	207,583	(201,663)
Deferred taxes on the results of subsidiaries abroad	(19,710)
Credits on exclusion of ICMS from the PIS/COFINS tax base	14,556	12,763
Other temporary differences	12,857	5,670
Closing balance	2,376,910	7,971,419

12.2 Reconciliation of the effects of income tax and social contribution on profit or loss


	06/30/2025	06/30/2024
Net income (loss) before taxes	17,255,357	(6,947,851)
Income tax and social contribution benefit (expense) at statutory nominal rate of 34%	(5,866,821)	2,362,269

Tax effect on permanent differences
Impact of the taxation difference on profit of associates in Brazil and abroad (1)	(294,581)	1,017,293
Equity method	(24,220)	(1,195)


Credit related to Reintegra Program	6,156	4,807
Director bonuses	(26,950)	(9,347)
Tax incentives (Note 12.3)	265,547	26,912
Donations/Fines – Other	45,643	1,626
	(5,895,226)	3,402,366
Income tax
Current	(206,328)	(370,788)
Deferred	(4,093,523)	2,852,815
	(4,299,851)	2,482,027
Social Contribution
Current	(104,206)	(99,416)
Deferred	(1,491,169)	1,019,755
	(1,595,375)	920,339
Income and social contribution benefits (expenses) on the period	(5,895,226)	3,402,366

(1)The difference in the taxation of subsidiaries is substantially due to the differences between the nominal tax rates in Brazil and those of subsidiaries located abroad.

12.3 Tax incentives

The Company benefits from a tax incentive for partial reduction of the income tax obtained from operations carried out in areas under the jurisdiction of the Northeast Development Superintendence (“SUDENE”) and the Superintendence of Amazon Development (“SUDAM”). The IRPJ reduction incentive is calculated based on the activity profits (exploitation profits) and considers the allocation of the operating profit based on the incentive production levels for each product.

Area/Regions

Company

Maturity

Northeast Development Superintendence (“SUDENE”)

Aracruz (ES)

Portocel

2030

Aracruz (ES)

Suzano

2031

Imperatriz (MA)

Suzano

2032

Mucuri (BA)

Suzano

2032

São Luís (MA)

Itacel

2033

Eunápolis (BA)

Veracel

2033

Superintendence of Amazon Development (“SUDAM”)

Belém (PA)

Suzano

2025

12.4 OECD PILLAR TWO MODEL RULES

In December 2021, the Organisation for Economic Co-operation and Development (“OECD”) announced the guidelines for the Pillar Two model, aiming for a reform in international corporate taxation to ensure that multinational economic groups, covered by such regulations, contribute an effective minimum tax at a rate of 15% on profits. Each country's effective profit tax rate, as calculated by this model, is called the GloBE (Global Anti-Base Erosion Rules) effective tax rate. These rules await approval in the local legislation of each country. In the context of Suzano, compliance with OECD guidelines on international taxation is a strategic priority.

Many countries have already released legislation or plans on the adoption of Pillar Two rules and the calculation of GloBE revenue, considering the global minimum rate of 15% for multinationals with consolidated revenue above EUR750 million.

Since 2024, the Company has been subject to these new rules in certain European jurisdictions where it operates, with Austria standing out as a relevant operation.

As of 2025, the Company is subject to the Additional Social Contribution on Net Income (CSLL), which is the Brazilian legislation's response to the GloBE rules and affects business groups with an IRPJ and CSLL tax burden of less than 15% in Brazil.

Based on the calculations performed under the GloBE Simplifying Transition Rules (RSGT), no impact on the financial statements is anticipated in relation to this matter.

The Company reaffirms its commitment to tax compliance and will continue to carry out the necessary actions to ensure the proper implementation of the new rule in the jurisdictions where it operates, in line with global best practices and current legislation.