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Provisions and contingent liabilities
12 Months Ended
Dec. 31, 2024
Provisions and contingent liabilities  
Provisions and contingent liabilities
18. Provisions and contingent liabilities 

Accounting policy

A provision for tax, civil and labor risks is recognized when there is a present obligation as a result of a past event, it is probable that a disbursement will be required to settle the obligation, and the amount can be reliably estimated, based on the opinion of Management and internal and external legal advisors, and the amounts are recognized based on estimates of the outcomes of the legal proceedings. The provision is recorded as an expense for the year. The update of this obligation is made according to the development of the legal proceeding or financial charges incurred and may be reversed if the loss estimate is no longer considered probable due to changes in circumstances, or when the obligation is settled. Contingent assets are disclosed when the associated economic benefits are probable and are only recognized in the financial statements in the period in which their realization is considered certain and their amount can be reliably measured.

a. Provisions for tax, civil and labor risks


The Company and its subsidiaries are parties to tax, civil and labor disputes at the administrative and judicial levels.


The table below presents the breakdown of provisions by nature and their changes:

Provisions

Balance as
of 12/31/2023


Additions


Reversals (1)


Payments/ write-offs


Interest


Balance as
of 12/31/2024


IRPJ and CSLL (a.1)

636,167


949


(15,124

)

(610,534

)

21,488


32,946


Tax

107,172


41,474


(72,427

)

(10,002

)

867


67,082


Civil, environmental and regulatory claims

150,258


66,215


(19,002

)

(35,519

)

20


161,972


Provision for indemnities (a.2)

203,780


19,519


(6,081

)

(12,959

)

2,549


206,808


Labor

59,144


18,468


(16,447

)

(7,764

)

768


54,169


Others

147,609


7,564


(15,148

)

(6,684

)

2,040


135,383


Total

1,304,130


154,189


(144,229

)

(683,462

)

27,732


658,360


Current

45,828










47,788


Non-current

1,258,302










610,572



(1) Of this amount, MR$ 28,612 corresponds to the reversals of updates.


Provisions

Balance as of 12/31/2022


Additions


Reversals


Payments


Interest


Acquisition of subsidiary


Balance as of 12/31/2023


IRPJ and CSLL (a.1)

559,217


14,597


(6,717

)


69,070



636,167


Tax

68,434


46,743


(21,148

)

(14,747

)

27,101


789


107,172


Civil, environmental and regulatory claims

93,416


124,857


(29,402

)

(39,071

)


458


150,258


Labor litigation

73,172


27,333


(27,308

)

(16,310

)

2,257



59,144


Provision for indemnities (a.2)

150,820


32,691


(7,969

)


28,238



203,780


Others

95,113


47,329


(8,031

)


13,198



147,609


Total

1,040,172


293,550


(100,575

)

(70,128

)

139,864


1,247


1,304,130


Current

22,837












45,828


Non-current

1,017,335












1,258,302



Provisions

Balance as of 12/31/2021


Additions


Reversals


Payments


Interest


Acquisition of subsidiary


Balance as of 12/31/2022


IRPJ and CSLL (a.1)

552,172


7,154


(36,683

)


36,574



559,217


Tax

84,155


35,238


(14,907

)

(38,097

)

2,045



68,434


Civil, environmental and regulatory claims

108,761


18,326


(9,980

)

(23,700

)

9



93,416


Labor litigation

95,460


22,663


(22,387

)

(23,142

)

578



73,172


Provision for indemnities (a.2)


150,820






150,820


Others

91,637


4,812


(3,850

)

-


2,514



95,113


Total

932,185


239,013


(87,807

)

(84,939

)

41,720




1,040,172


Current

119,942












22,837


Non-current

812,243












1,017,335



Balances of escrow deposits by nature are as follows:


12/31/2024


12/31/2023


Tax (a.1)

306,593


856,830


Labor

24,070


37,715


Civil and others

115,413


138,172



446,076


1,032,717


In the year ended December 31, 2024, the monetary variation on escrow deposits amounted to R$ 45,336 (R$ 62,217 as of December 31, 2023 and R$ 26,969 as of December 31, 2022), recorded with a corresponding entry to financial income in profit or loss.

a.1 Provision for tax matters

On October 7, 2005, subsidiaries Ultragaz and Bahiana filed a writ of mandamus, in which a preliminary injunction was granted, later confirmed in a favorable lower court ruling on May 16, 2008. The decision authorized the offsetting of PIS and COFINS credits on the acquisition of LPG against debts from other federal taxes, and required them to make escrow deposits until the outcome of the litigation. On July 18, 2014, after an appellate court unfavorable decision, aligned with the STJ case law (Case 1.093), the subsidiaries suspended the escrow deposits and resumed the payment of the taxes. On October 21, 2024, with the withdrawal of the proceeding and a final and unappealable decision, the provision relating to this thesis was reverted and the escrow deposits, in the amount of R$ 621,009, were fully drawn down by the Federal Government, with no impact on profit or loss.

a.2 Provision for indemnities

On April 1, 2022, Ultrapar concluded the sale of Oxiteno, assuming the responsibility for losses resulting from acts that occurred prior to the closing of the transaction, pursuant to the purchase and sale agreement. The total provision recorded for the reimbursement to Indorama, in the event the losses materialize, is R$ 174,408 (R$ 168,567 as of December 31, 2023), of which R$ 95,274 (R$ 92,823 as of December 31, 2023) for labor claims, R$ 26,074 (R$ 17,584 as of December 31, 2023) for civil claims and R$ 53,060 (R$ 58,160 as of December 31, 2023) for tax claims.

On August 1, 2022, Ultrapar also concluded the sale of Extrafarma with subsidiary Ipiranga assuming the responsibility for losses prior to the closing of the transaction. Thus, a provision for the reimbursement to Pague Menos was recorded, in the event the losses materialize, totaling R$ 32,400 as of December 31, 2024 (R$ 35,074 as of December 31, 2023) referring to the provision for indemnity, of which R$ 12,074 (R$ 16,259 as of December 31, 2023) for labor claims, R$ 7,007 (R$ 6,420 as of December 31, 2023) for civil claims and R$ 13,319 (R$ 12,395 as of December 31, 2023) for tax claims.

b. Contingent liabilities (possible)

The Company and its subsidiaries are parties to tax, civil, environmental, regulatory, and labor claims whose likelihood of loss is assessed by the legal departments of the Company and its subsidiaries as possible, based on the analysis and opinion of their external legal advisors. Based on these assessments, no provision for these contingencies was recorded in the financial statements.

Contingent liabilities (possible)

12/31/2024


12/31/2023


Tax (b.1)

4,176,046


3,148,224


Civil (b.2)

815,203


624,653


Labor

293,938


240,515



5,285,187


4,013,392



b.1 Contingent tax liabilities

The Company and its subsidiaries are also parties to administrative and judicial proceedings involving IRPJ, CSLL, PIS and COFINS, substantially involving denials of offset claims and credit disallowance which total R$ 2,049,421 in December 31, 2024 (R$ 1,394,010 as of December 31, 2023), mainly represented by a tax assessment related to the IRPJ and CSLL resulting from the alleged undue amortization of the goodwill paid on the acquisition of investments, in the amount of R$ 266,619 as of December 31, 2024 (R$ 251,789 as of December 31, 2023).

Additionally, subsidiary Ipiranga and its subsidiaries have legal proceedings related to ICMS totaling R$ 1,357,445 as of December 31, 2024 (R$ 1,380,424 as of December 31, 2023). The main proceedings include: i) credits considered undue in the amount of R$ 94,640 as of December 31, 2024 (R$ 149,061 as of December 31, 2023), ii) alleged non-payment in the amount of R$ 154,914 as of December 31, 2024 (R$ 196,693 as of December 31, 2023); iii) conditioned fruition of tax incentive in the amount of R$ 191,549 as of December 31, 2024 (R$ 193,912 as of December 31, 2023); iv) inventory differences in the amount of R$ 279,448 as of December 31, 2024 (R$ 282,254 as of December 31, 2023); v) 2% surcharge on products considered non-essential (hydrated ethanol) in the amount of R$ 223,691 as of December 31, 2024 (R$ 271,518 as of December 31, 2023).

In addition, subsidiary Ipiranga and its subsidiaries are discussing the offset of excise tax (“IPI”) credits related to raw materials used in the manufacturing of products subject to taxation, which were subsequently sold and were not subject to IPI under the tax immunity. The amount of this contingency is R$ 194,508 as of December 31, 2024 (R$ 185,388 as of December 31, 2023).

b.2 Contingent civil liabilities

The main contingent civil liabilities refers to Ultragaz totaling R$ 187,460 as of December 31, 2024 (R$ 113,756 as of December 31, 2023) were filed by resellers seeking indemnity, nullity and termination of distribution agreements.

c. Lubricants operation between Ipiranga and Chevron

The provisions of shareholder Chevron’s liability amount to R$ 36,146 (R$ 29,022 as of December 31, 2023), for which an indemnity asset was recorded, referring mainly to: i) R$ 32,380 (R$ 25,777 as of December 31, 2023) in ICMS assessments on sales for industrial purposes, in which the STF closed the judgment of the thesis unfavorably to taxpayers; ii) R$ 3,545 (R$ 3,020 as of December 31, 2023) in labor claims.

Additionally, due to a business combination, on December 1, 2017, a provision of R$ 198,900 was recorded relating to contingent liabilities and an indemnification asset in the same amount was recognized, with a current balance of R$ 89,952 as of December 31, 2024 (R$ 95,905 as of December 31, 2023). The amounts of provisions and contingent liabilities related to the business combination and the liability of the shareholder Chevron will be reimbursed to subsidiary Iconic in the event of losses without the need to recognize an allowance for expected credit losses.