XML 30 R18.htm IDEA: XBRL DOCUMENT
v3.23.2

Taxes | 12 Months Ended
--- | ---
Dec. 31, 2022
Taxes |
Taxes |
12. | Taxes
| 12.1 | Deferred income tax and social contribution
Schedule of Deferred income tax and social contribution |  |  |  |  |  |  |  |  |  |
| Balance as of January 1, 2021 | Recognized in income | Other (a) | Reclassification (a) | Recognized comprehensive income | Balance as of December 31, 2021 | Recognized in income | Other (b) | Recognized comprehensive income | Balance as of December 31, 2022
Noncurrent assets |  |  |  |  |  |  |  |  |  |
Provisions for legal claims | 499,375 | 7,291 | - | (2,205) | - | 504,461 | 132,175 | - | - | 636,636
Provision for allocation of PIS and Cofins credits | - | - | - | - | - | - | 629,427 | - | - | 629,427
Post-employment benefits | 507,032 | (766) | - | 16,875 | (93,881) | 429,260 | 22,724 | - | (88,548) | 363,436
Impairment of assets | 310,606 | (6,456) | - | (1,753) | - | 302,397 | (17,486) | - | - | 284,911
Tax losses and negative tax basis | 215,389 | 54,416 | (148,005) | 1,210 | - | 123,010 | 73,260 | - | - | 196,270
Research and development and energy efficiency programs | 152,498 | (13,649) | - | - | - | 138,849 | (11,766) | - | - | 127,083
Expected credit losses | 123,182 | (21,476) | - | (2,994) | - | 98,712 | (11,412) | - | - | 87,300
Social security contributions - injunction on judicial deposit | 70,992 | 3,673 | - | 78 | - | 74,743 | 7,516 | - | - | 82,259
Amortization - concession | 47,209 | 5,220 | - | - | - | 52,429 | 5,220 | - | - | 57,649
Provisions for performance andprofit sharing | 160,459 | (45,866) | - | - | - | 114,593 | (100,957) | - | - | 13,636
Concession contracts | 21,061 | (1,292) | - | - | - | 19,769 | (1,067) | - | - | 18,702
Voluntary retirement program | 10,815 | 13,493 | - | - | - | 24,308 | (22,551) | - | - | 1,757
Others | 149,662 | 1,457 | 1,062 | 5,905 | - | 158,086 | 23,792 | - | - | 181,878
| 2,268,280 | (3,955) | (146,943) | 17,116 | (93,881) | 2,040,617 | 728,875 | - | (88,548) | 2,680,944
(-) Noncurrent liabilities |  |  |  |  |  |  |  |  |  |
Concession contracts | 900,505 | 808,372 | 94,221 | - | - | 1,803,098 | 52,617 | 8,155 | - | 1,863,870
Deemed cost of property, plant and equipment | 350,491 | (23,994) | - | - | - | 326,497 | (18,810) | - | - | 307,687
Accelerated depreciation | 75,955 | 26,369 | - | - | - | 102,324 | 25,832 | - | - | 128,156
Derivative financial instruments | 117,682 | (12,178) | - | - | - | 105,504 | 11,134 | - | - | 116,638
Escrow deposits monetary variation | 61,727 | 3,392 | - | - | - | 65,119 | 7,708 | - | - | 72,827
Transaction cost on loans and financing and debentures | 23,203 | 4,833 | - | - | - | 28,036 | 2,280 | - | - | 30,316
Others | 31,951 | (20,343) | - | - | - | 11,608 | 19,725 | - | 3,500 | 34,833
| 1,561,514 | 786,451 | 94,221 | - | - | 2,442,186 | 100,486 | 8,155 | 3,500 | 2,554,327
Net | 706,766 | (790,406) | (241,164) | 17,116 | (93,881) | (401,569) | 628,389 | (8,155) | (92,048) | 126,617
Assets presented in the Statement of Financial Position | 1,011,866 |  |  |  |  | 963,259 |  |  |  | 1,644,299
Liabilities presented in the Statement of Financial Position | (293,666) |  |  |  |  | (1,364,828) |  |  |  | (1,517,682)
(a) | Effects of the business combination and discontinued operation detailed in the Financial Statements as of December 2021.
(b) | Effects of the business combination (Note 1.1.1).
| 12.1.1 | Projection for realization of deferred income tax and social contribution:
The projection of deferred tax credits realization recorded in noncurrent assets and liabilities is based on the realization period of each item of deferred assets and liabilities and tax losses, also based on projections of future results. These projections were evaluated by the Supervisory Board and approved by the Board of Directors on March 21, 2022. The criteria used for the realization of each item are related to the predictability of realization of the main value that gave rise to the temporary difference. When the expectation of realization of the item is difficult to predict, mainly because it is not under the control of the Company, such as provisions for litigation, the Company adopts history of realization to project its future realization. The realization of the amounts of income tax and social contribution losses follow the potential compensation considering future profits and the limit defined by the legislation. Following are the items that were the basis for the setup of the main credits, as well as their form of realization: - Provision for allocation of PIS and Cofins credits: will be carried out as the amounts are passed on in the tariff review and readjustment processes approved by the regulatory body, if any, or by the reversal of the respective provision; - Provisions for post-employment benefits: realized as the payments are made to the Copel Foundation or reversed according to new actuarial estimates; - Provisions for legal claims: realized according to court decisions or by the reversal when the possible risk of the shares is reviewed; - Impairment of assets: realized through the amortization and/or depreciation of the impaired asset; - Deemed cost: realized through the amortization and/or depreciation of the valued asset; - Amounts related to the concession agreement: realized over the term of the agreement; - Amounts related to tax losses and negative tax basis: recovered by offsetting against future taxable income; - Other amounts: realized when they meet the deductibility criteria provided for in tax legislation, or upon reversal of the recorded amounts. The projected realization of the deferred taxes is shown below:
The projected realization of the deferred taxes |  |
| Assets | Liabilities
2023 | 360,933 | (232,236)
2024 | 417,270 | (282,299)
2025 | 486,215 | (228,450)
2026 | 128,402 | (227,274)
2027 | 102,221 | (178,671)
2028 to 2030 | 234,464 | (454,087)
after 2030 | 951,439 | (951,310)
| 2,680,944 | (2,554,327)
| 12.1.2 | Unrecognized tax credits
As of December 31, 2022, Company did not recognize income tax and social contribution credits on income tax and social contribution tax losses in the amount of R$197,540 (R$68,826, as of December 31, 2021) for not having reasonable assurance of generation of future taxable profits sufficient to allow the utilization of these tax credits.
| 12.2 | Other taxes recoverable and other tax obligations
Summary Of Other Recoverable Taxes And Other Taxes |  |
| 12.31.2022 | 12.31.2021
Current assets |  |
Recoverable ICMS (VAT) | 128,288 | 111,101
Recoverable PIS/Pasep and Cofins taxes (a) | 1,110,659 | 1,396,645
Other recoverable taxes | 747 | 1,118
| 1,239,694 | 1,508,864
Noncurrent assets |  |
Recoverable ICMS (VAT) | 171,374 | 141,951
Recoverable PIS/Pasep and Cofins taxes (a) | 2,421,176 | 2,967,756
Other recoverable taxes | 34,743 | 33,839
| 2,627,293 | 3,143,546
Current liabilities |  |
ICMS (VAT) payable(Note 12.2.3) | 149,506 | 290,627
ICMS installment payment (Note 12.2.4) | 10,437 | -
PIS/Pasep and Cofins payable | 70,423 | 42,340
IRRF on interest on capital | 11,372 | 33,592
Special Tax Regularization Program - Pert | 57,046 | 52,168
Other taxes | 4,822 | 22,206
| 303,606 | 440,933
Noncurrent liabilities |  |
Social security contributions - injunction on judicial deposit | 242,248 | 220,108
ICMS installment payment (Note 12.2.4) | 37,883 | -
Special Tax Regularization Program - Pert | 347,029 | 369,526
Other taxes | 6,331 | 5,176
| 633,491 | 594,810
(a) | The balance contains amounts referring Pis and Cofins credit on ICMS (Notes 12.2.1 and 12.2.2)
| 12.2.1 | Pis and Cofins credit on ICMS - Copel Distribuição
On August 12, 2009, Copel DIS filed for a writ of mandamus No. 5032406-35.2013.404.7000 with the 3rd Federal Court of Curitiba applying for the granting of an order to stop including ICMS in the PIS and Cofins tax base on June 16, 2020, a final unappealable ruling was handed down by the 2nd Panel of the Federal Regional Court of the 4th Region recognizing the right of Copel DIS to exclude from the PIS and Cofins tax base the full amount of ICMS included in the energy supply and distribution invoices. The ruling also recognized that the limitation period, in this case, is of five years and that, therefore, Copel has the right to recover the amounts that have been paid during the five years preceding the filing of the writ of mandamus until the date of the final unappealable decision. Based on this favorable decision, Copel DIS recognized the tax credit updated in assets, which has been recovered through offsetting with taxes payable since June 2021, from the qualification of the credit originating from Cofins with the Brazilian Federal Revenue Service. The credit originating from PIS was qualified by the Brazilian Federal Revenue Service on August 25, 2022 and is ready to be used through offsetting. On May 13, 2021, the Federal Supreme Court concluded the judgment of the motions for clarification filed by the Federal Government in Extraordinary Appeal 574.706/PR, partially granting the following terms: (i) relating to ICMS excluded from the PIS and Cofins calculation basis, the understanding that it is the highlighted ICMS prevailed; and (ii) modulate the effects of the judgment whose production will take place after March 15, 2017, except for the judicial and administrative actions filed up to the date of the session in which the judgment was delivered. Therefore, the final decision on this matter did not impact the final and unappealable decision in favor of Copel DIS, maintaining the treatment and amounts recorded. The following table shows the movement of the asset until December 31, 2022:
Other taxes recoverable and other tax obligations |  |
Balance as of January 1, 2021 |  | 5,655,754
Monetary variation |  | 125,483
Offsetting with taxes payable |  | (1,425,972)
Balance as of December 31, 2021 |  | 4,355,265
Monetary variation |  | 294,952
Offsetting with taxes payable |  | (1,165,601)
Balance as of December 31, 2022 |  | 3,484,616
| Current | 1,148,897
| Noncurrent | 2,335,719
The asset balance will continue to be offset against future federal tax debts. a) Liabilities to be refunded to consumers The Company recorded a liability to be refunded to consumers related to the recovery of tax credits for the last 10 years, counting from the date of the final and unappealable decision, considering the current legislation, the statute of limitations period defined in the civil code and the jurisprudence of the courts. On February 09, 2021, Aneel opened Public Consultation No. 05/2021 aimed at discussing how to return tax credits to consumers, proposing that the amounts to be returned for each tariff cycle (credits with the Brazilian Federal Revenue Office, added to any judicial deposits already received by the concessionaire/permissionaire) are deducted from the electricity bill, through apportionment by the set of consumers. Additionally, Aneel Order No. 361/2021 established that in exceptional situations, in which there is a possibility of a significant tariff increase, part of the PIS and Cofins credits may be used in advance of the conclusion of the public consultation, limited to 20% of the total involved in lawsuits filed by distributors. In the tariff adjustment of June 24, 2022, the total of R$1,593,100 was considered as a financial item, so this balance was transferred to the sectorial financial liabilities account, as shown in the following table:
Liabilities to be refunded to consumers |  |
Balance as of January 1, 2021 |  | 3,927,824
Monetary variation |  | 100,971
(-) Transfer to sectorial financial liabilities (Note 8) |  | (702,000)
Balance as of December 31, 2021 |  | 3,326,795
Monetary variation |  | 261,463
(-) Transfer to sectorial financial liabilities (Note 8) |  | (1,593,100)
Balance as of December 31, 2022 |  | 1,995,158
| Current | 550,527
| Noncurrent | 1,444,631
The balance of the liability will be refunded to the consumer as the tax credits in the asset are offset. b) Provision for allocation of PIS and Cofins credits On June 27, 2022, Federal Law No. 14,385 was enacted, which defines the allocation of mandatory tax amounts collected in excess by the providers of the public electricity distribution service, due to the recognition by the judiciary that ICMS should be excluded from the PIS and Cofins calculation basis. As detailed earlier in this note, Copel DIS has recognized the right to exclude the full amount of ICMS from the PIS and Cofins calculation basis and has already transferred part of these amounts to consumers, through reductions in the tariff adjustments approved by Aneel. In this context, despite the lack of regulation of this Law, based on the review of the risk assessment carried out by Management, Copel DIS decided to recognize an additional provision, with no immediate cash effect, referring to the period between the 11th and the 16th year from the date of the final and unappealable decision of the lawsuit. The Management of Copel DIS understands that the refund to consumers is limited to the tax credit amounts of the last 10 years from the date of the final and unappealable decision and, therefore, is evaluating the appropriate measures to be taken, including legal measures, considering the shelter given to unappealable decisions and applicable limitation periods. On December 12, 2022, the Brazilian Association of Electric Energy Distributors - Abradee filed a Direct Action of Unconstitutionality - ADI with the Federal Supreme Court - STF, questioning Law No. 14,385/2022, which has not yet been judged. The Company awaits the unfolding of the ADI. The table below shows the changes in the provision until December 31, 2022:
Provision for allocation of PIS and Cofins credits |  |
Balance as of January 1, 2022 |  | -
Provision for allocation of PIS and Cofins credits |  | 810,563
Monetary variation |  | 1,011,370
Balance as of June 30, 2022 |  | 1,821,933
Monetary variation |  | 29,324
Balance as of December 31, 2022 |  | 1,851,257
Any allocation of this provision will occur only after the asset's tax credits are offset.
| 12.2.2 | PIS and Cofins credit on ICMS - Compagas
Balance arising from the final and unappealable decision of the lawsuit in which Compagas discussed the exclusion of ICMS from the PIS and Cofins calculation basis. In view of the favorable decision, Compagas recorded assets of R$107,453 in September 2019. Most of these credits have already been recovered and the restated balance on 12.31.2022 is R$28,505 (R$75,192 on December 31, 2021) with achievement expectation in 2023.
| 12.2.3 | ICMS on electricity operations
Supplementary Law No. 194/2022 was published on June 23, 2022, prohibiting that ICMS rates be set on electricity transactions at a level higher than on general transactions, considering the essentiality of related goods and services. Furthermore, it set forth that ICMS is not levied on transmission and distribution services and sector charges related to electric energy transactions. In compliance with the law, and after issue of state tax authorities’ opinions, the Company implemented the necessary changes in September 2022 to comply with the legislation. However, on February 9, 2023, the Brazilian Supreme Court - STF granted States, in a preliminary decision, in the records of Direct Action of Unconstitutionality - ADI 7195, suspension of the article that excluded such items from the taxed portion of the electricity bill. Considering this decision, the Company resumed ICMS taxation on said services and sector charges. On March 3, 2023, the preliminary injunction was approved by the Plenary of the STF.
| 12.2.4 | Incentive installment payment program for ICMS tax credits in the State of Paraná
On September 27, 2022, the Company adhered to the installment payment program for previously recognized ICMS, established by the State of Paraná through State Law No. 20946/2021, regulated by State Decree No. 10766/2022, wherein R$92,249 debts were entered in its report of tax position, updated until September 2022 with fine, interest and monetary restatement. By adhering to said program, the Company reduced R$41,696 in charges, with a consolidated balance of R$50,553 at the adhesion date, to be paid in 60 monthly installments until September 2027, according to the mentioned program regulation. The Company has been paying the monthly installments on a regular basis, restated by the Selic rate.
| 12.3 | Reconciliation of provision for income tax (IRPJ) and social contribution (CSLL)
The income tax and social contribution credits to be recovered presented in the balance sheet of December 31, 2022, in the amount of R$482,887, refer mainly to the calculation of negative balances that will be offset against federal taxes payable. The table below demonstrates the reconciliation of IRPJ and CSLL recorded in income for the year:
Summary Of Reconciliation Of Provision For Income Tax And Social Contribution |  |  |
| 12.31.2022 | 12.31.2021 | 12.31.2020
Income before IRPJ and CSLL | 950,199 | 5,118,677 | 5,119,537
(-) Equity in income | (478,576) | (366,315) | (193,547)
Income after IRPJ and CSLL | 471,623 | 4,752,362 | 4,925,990
IRPJ and CSLL (34%) | (160,352) | (1,615,803) | (1,674,837)
Tax effects on: |  |  |
Interest on equity (JSCP) | 335,697 | 226,928 | 276,808
Dividends | 250 | 437 | 243
Non deductible expenses | (26,221) | (25,336) | (17,133)
Tax incentives | 13,767 | 43,720 | 28,572
Unrecognized tax loss and negative basis of CSLL | (128,661) | (29,002) | (39,421)
Setting up and/or offset of income tax and social contribution losses of prior years | - | 85,723 | -
Difference between tax bases of deemed profit and taxable profit | 35,677 | 49,638 | 121,242
Effect of non taxable monetary variation (Selic) on undue tax payments | 100,282 | - | -
Others | 28,683 | 4,063 | 19,161
Current IRPJ and CSLL | (429,267) | (469,226) | (1,260,469)
Deferred IRPJ and CSLL | 628,389 | (790,406) | (24,896)
Effective rate - % | -42.2% | 26.5% | 26.1%

X
- References No definition available. + Details
Name: | elp_TaxesAbstract
Namespace Prefix: | elp_
Data Type: | xbrli:stringItemType
Balance Type: | na
Period Type: | duration

X
- Definition The entire disclosure for income taxes. + References Reference 1: http://www.xbrl.org/2003/role/disclosureRef -Name IAS -Number 12 -IssueDate 2022-03-24 -Section Disclosure -URI https://taxonomy.ifrs.org/xifrs-link?type=IAS&num=12&code=ifrs-tx-2022-en-r&doctype=Standard&dita_xref=IAS12_g79-88__IAS12_g79-88_TI -URIDate 2022-03-24 + Details
Name: | ifrs-full_DisclosureOfIncomeTaxExplanatory
Namespace Prefix: | ifrs-full_
Data Type: | dtr-types:textBlockItemType
Balance Type: | na
Period Type: | duration