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Income and Social Contribution Taxes | 12 Months Ended
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Dec. 31, 2023
Disclosure of income and social contribution taxes [abstract] |
Income and Social Contribution Taxes | 9 Income and social contribution taxes a. Deferred income (IRPJ) and social contribution taxes (CSLL) The Company and its subsidiaries recognize deferred tax assets and liabilities, which are not subject to the statute of limitations, mainly resulting from provision for differences between cash and accrual basis, tax loss carryforwards and provisions for tax, civil, and labor risks. Deferred tax assets are sustained by the continued profitability of their operations. Deferred IRPJ and CSLL are recognized under the following main categories:
| 12/31/2023 |  |  | 12/31/2022 |
Assets - deferred income and social contribution taxes on: |  |  |  |  |
Provision for losses with assets | 46,863 |  |  | 47,436 |
Provisions for tax, civil and labor risks | 326,662 |  |  | 225,585 |
Provision for post-employment benefits | 90,451 |  |  | 74,644 |
Provision for differences between cash and accrual basis (i) | 35,989 |  |  | 63,330 |
Goodwill | 7,976 |  |  | 3,561 |
Business combination – tax basis vs. accounting basis of goodwill | - |  |  | 17,575 |
Provision for asset retirement obligation | 14,759 |  |  | 15,737 |
Operating provisions | 299,609 |  |  | 132,657 |
Provision for profit sharing and bonus | 91,883 |  |  | 69,588 |
Leases payable | 518,138 |  |  | 518,081 |
Change in fair value of subscription warrants | 3,566 |  |  | 9,224 |
Provision for deferred revenue | 932 |  |  | 8,121 |
Other temporary differences | 104,319 |  |  | 43,715 |
Tax losses and negative basis for social contribution carryforwards (9.d) | 396,601 |  |  | 283,238 |
Total | 1,937,748 |  |  | 1,512,492 |
Offsetting liability balance | (682,614 | ) |  | (614,257 | )
Net balances of deferred tax assets | 1,255,134 |  |  | 898,235 |
Liabilities - deferred income and social contribution taxes on: |  |  |  |  |
Revaluation of property, plant and equipment | ‐ |  |  | 387 |
Leases payable | 432,908 |  |  | 457,768 |
Provision for differences between cash and accrual basis (i) | 81,293 |  |  | 9,389 |
Goodwill | 28,717 |  |  | 27,691 |
Business combination - fair value of assets | 54,921 |  |  | 61,521 |
Other temporary differences | 84,981 |  |  | 57,800 |
Total | 682,820 |  |  | 614,556 |
Offsetting asset balance | (682,614 | ) |  | (614,257 | )
Net balance of deferred tax liabilities | 206 |  |  | 299 |
(i) Refers mainly to the income and social contribution taxes on the exchange variation of the derivative instruments. Changes in the net balance of deferred IRPJ and CSLL are as follows:
Balance as of December 31, 2020 | 961,979 |
Deferred IRPJ and CSLL recognized in income for the year | 242,246 |
Deferred IRPJ and CSLL of subsidiaries classified as discontinued operations | 110,821 |
Deferred IRPJ and CSLL recognized in other comprehensive income | (11,366 | )
Reclassification to assets held for sale | (728,986) |
Others | (3,221 | )
Balance as of December 31, 2021 | 571,473 |
Deferred IRPJ and CSLL recognized in income for the year | 296,459 |
Deferred IRPJ and CSLL recognized in income for the year from discontinued operation | 31,138 |
Deferred IRPJ and CSLL recognized in other comprehensive income | (1,134 | )
Balance as of December 31, 2022 | 897,936 |
Deferred IRPJ and CSLL recognized in income for the year | 335,375 |
Deferred IRPJ and CSLL recognized in other comprehensive income | 21,474 |
Others | 143 |
Balance as of December 31, 2023 | 1,254,928 |
The balance of the Company of R$ 1,255,134 was supported by the study on taxable profit projections for the realization of deferred tax assets in order to the realization of deferred tax assets. The taxable profit projections were made considering the business plans of each segment of the Company which indicates trends and perspectives, demand effects, competition, and other economic factors, and that represent the management’s best estimate about the economic conditions existing during the period of realization of the deferred tax asset were taken into account. The main key assumptions used to calculate the realization of deferred tax assets are: growth in Gross Domestic Product (“GDP”), exchange rate, basic interest rate (SELIC) and DI, inflation rate, commodity price index, among others. b. Reconciliation of income and social contribution taxes in the statement of income IRPJ and CSLL are reconciled to the statutory tax rates as follows:
| 2023 |  |  | 2022 |  |  | 2021 |
Income before taxes | 3,578,695 |  |  | 1,879,725 |  |  | 1,006,648 |
Statutory tax rates - % | 34 |  |  | 34 |  |  | 34 |
Income and social contribution taxes at the statutory tax rates | (1,216,756 | ) |  | (639,107 | ) |  | (342,260 | )
Adjustment to the statutory income and social contribution taxes: |  |  |  |  |  |  |  |
Nondeductible expenses (i) | (11,535 | ) |  | (11,006 | ) |  | (45,569 | )
Nontaxable revenues (ii) | 114,981 |  |  | 23,149 |  |  | 138,631 |
Adjustment to estimated income (iii) | 2,173 |  |  | 10,136 |  |  | 3,901 |
Unrecorded deferred income and social contribution tax carryforwards (iv) | (36,227 | ) |  | (4,602 | ) |  | (5,285 | )
Share of profit (loss) of subsidiaries, joint ventures and associates | 4,049 |  |  | 4,141 |  |  | (5,995 | )
Interest on capital | ‐ |  |  | 153,004 |  |  | ‐ |
Other adjustments | (26,666 | ) |  | 29,327 |  |  | 21,414 |
Income and social contribution taxes before tax incentives | (1,169,981 | ) |  | (434,958 | ) |  | (235,163 | )
Tax incentives – SUDENE (9.c) | 109,039 |  |  | 93,444 |  |  | 47,129 |
Income and social contribution taxes in the statement of income | (1,060,942 | ) |  | (341,514 | ) |  | (188,034 | )
Current | (1,396,317 | ) |  | (637,973 | ) |  | (430,280 | )
Deferred | 335,375 |  |  | 296,459 |  |  | 242,246 |
Effective IRPJ and CSLL rates - % | (29.6 | ) |  | (18.2 | ) |  | (18.7 | )
(i) | Consist of certain expenses that cannot be deducted for tax purposes under applicable tax legislation, such as expenses with fines, donations, gifts, losses of assets, negative results of foreign subsidiaries and certain provisions.
(ii) | Consist of certain gains and income that are not taxable under applicable tax legislation, such as the reimbursement of taxes, tax incentives, installments and the reversal of certain provisions, as well as recovery of tax credits and amounts related to non-taxation of the income and social contribution taxes on the monetary adjustment (SELIC) in the repetition of undue tax lawsuits.
(iii) | Brazilian tax law allows for an alternative method of taxation for companies that generated gross revenues of up to R$ 78 million in their previous fiscal year. Certain subsidiaries of the Company adopted this alternative form of taxation, whereby income and social contribution losses are calculated on a basis equal to 32% of the operating revenues, as opposed to being calculated based on the effective taxable income of these subsidiaries. The adjustment to estimated income represents the difference between the taxation under this alternative method and the income and social contribution taxes that would have been paid based on the effective statutory rate applied to the taxable income of these subsidiaries.
(iv) | See Note 9.d.
c. Tax incentives – SUDENE The following subsidiaries have the benefit of income tax reduction for belonging to the sectors of the economy considered priority for the subsidized areas, under the terms of the development program of the region operated by the Superintendence for the Development of the Northeast (“SUDENE”), in compliance with the current law:
Subsidiary | Units |  |  | Incentive - % |  |  | Expiration |
Bahiana Distribuidora de Gás Ltda. | Mataripe base |  |  | 75 |  |  | 2024 |
| Caucaia base |  |  | 75 |  |  | 2025 |
| Juazeiro base |  |  | 75 |  |  | 2026 |
| Aracaju base |  |  | 75 |  |  | 2027 |
| Suape base |  |  | 75 |  |  | 2027 |
Ultracargo Logística S.A. | Aratu Terminal(1) |  |  | 75 |  |  | 2032 |
| Suape Terminal |  |  | 75 |  |  | 2030 |
| Itaqui Terminal |  |  | 75 |  |  | 2030 |
(1) | In December 2022, an application for renewal of Aratu Terminal concession term for an additional 10 years was filed with SUDENE, having been approved in accordance with Report 108/2023 and recognition by the Brazilian Federal Revenue with effect on January 1, 2023.
d. Tax losses and negative basis for social contribution carryforwards As of December 31, 2023, the Company and certain subsidiaries had tax loss carryforwards related to income tax (IRPJ) and social contribution (CSLL), whose annual offsets are limited to 30% of taxable income in a given tax year, which do not expire. The balances comprising deferred taxes related to income tax loss carryforwards and negative basis of social contribution are as follows:
| 12/31/2023 |  |  | 12/31/2022 |
Oil Trading | 84,372 |  |  | 93,627 |
Ultrapar (i) | 77,453 |  |  | 65,505 |
Abastece Aí | 91,861 |  |  | 66,347 |
Ipiranga | 97,071 |  |  | 28,894 |
Ultracargo Vila do Conde | 30,652 |  |  | 22,313 |
Others | 15,192 |  |  | 6,552 |
| 396,601 |  |  | 283,238 |
(i) Include the amount of R$ 25,884 of deferred taxes recognized on the tax loss of subsidiary Ultrapar International as of December 31, 2023 (R$ 33,663 as of December 31, 2022). The balances which are not constituted of deferred taxes related to income tax loss carryforwards and negative basis of social contribution are as follows:
| 12/31/2023 |  |  | 12/31/2022 |
Neogás | 45,333 |  |  | - |
Integra Frotas | 13,335 |  |  | 12,394 |
Millennium | 8,539 |  |  | 6,154 |
Others | 9,095 |  |  | 997 |
| 76,302 |  |  | 19,545 |
e. Non-levy of IRPJ/CSLL on the update by Selic of tax undue payments received from the Federal Government The Company and its subsidiaries have lawsuits claiming the non-levy of IRPJ and CSLL on monetary variation (SELIC) on tax credits. On September 27, 2021, the Federal Supreme Court judged that the levy of IRPJ and CSLL on amounts related to monetary variation (SELIC) received by taxpayers in the repetition of undue tax payments is unconstitutional. The Company and its subsidiaries have registered credits of this nature in the amount of R$ 143,147 as of December 31, 2023 (R$ 128,420 as of December 31, 2022).

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