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PROVISIONS FOR TAX, SOCIAL SECURITY, LABOR, CIVIL AND ENVIRONMENTAL RISKS AND JUDICIAL DEPOSITS (Tables)
12 Months Ended
Dec. 31, 2024
Provisions For Tax Social Security Labor Civil And Environmental Risks And Judicial Deposits  
Schedule of accrued amounts and judicial deposits
               
                Consolidated
    Accrued liabilities   Judicial deposits
    12/31/2024   12/31/2023   12/31/2024   12/31/2023
Tax   130,755   154,626   176,086   153,715
Social security   1,546   1,609       4
Labor   387,612   366,645   294,233   288,389
Civil   815,180   778,796   134,609   24,880
Environmental   42,609   41,194   3,723   3,340
Deposit of a guarantee           24,299   21,554
    1,377,702   1,342,870   632,950   491,882
                 
Classified:                
Current   132,112   36,000        
Non-current   1,245,590   1,306,870   632,950   491,882
    1,377,702   1,342,870   632,950   491,882
Schedule of changes in the provision for tax, social security, labor, civil and environmental risks
                   
                    Consolidated
                    Current + Non-current
Nature   12/31/2023   Additions   Accrued charges   Net utilization of reversal   12/31/2024
Tax   154,626    44,450    3,752    (72,073)   130,755
Social security    1,609     61   (124)   1,546
Labor   366,645    81,766    36,799    (97,598)   387,612
Civil   778,796    55,041    58,616    (77,273)   815,180
Environmental    41,194   816    2,764    (2,165)   42,609
     1,342,870   182,073   101,992    (249,233)   1,377,702
Schedule of legal matters with possible risk of loss
       
        Consolidated
    12/31/2024   12/31/2023
Notice of Violation and Imposition of Fine (AIIM) / Tax Foreclosure - RFB - IRPJ/CSLL - Capital Gain for alleged sale of equity interest in subsidiary NAMISA (1)   10,246,424   15,606,600
         
Notice of Violation and Imposition of Fine (AIIM) / Tax Foreclosure - RFB - IRPJ/CSLL - Disallowance of goodwill deductions generated in the reverse incorporation of Big Jump by Namisa (1)   4,346,118   5,443,666
         
Notice of Violation and Imposition of Fine (AIIM) / Tax Enforcement - RFB - IRPJ/CSLL - Disallowance of prepayment interest arising from iron ore supply and port services contracts   2,284,914   2,124,479
         
Notice of Violation and Imposition of Fine (AIIM) / Writ of Mandamus - RFB - IRPJ/CSLL - Profits earned abroad in 2008, 2010, 2011, 2012, 2014, 2015, 2016, 2017 and 2018   6,239,017   5,828,921
         
Unapproved compensation - RFB - IRPJ/CSLL, PIS/COFINS and IPI   2,169,108   2,052,564
         
ICMS - SEFAZ/RJ - Assessment Notice -  questions about sales for incentive area   1,460,763   1,016,381
         
Notice of Violation and Imposition of Fine (AIIM) - RFB - Disallowance of PIS/COFINS Credits for inputs and freight   1,499,578   1,388,918
         
CFEM – difference of understanding between CSN and ANM on the calculation basis   1,570,733   1,452,933
         
Notice of Infraction and Imposition of Fine (AIIM) - RFB - Collection IRRF - Business Combinations CMIN 2015(2)   205,621   1,106,401
         
ICMS - SEFAZ/RJ - ICMS Credits for acquisition of Electric Energy Industrialization (3)   39,939   1,065,918
         
Notice of Violation and Imposition of Fine (AIIM) - IRPJ/CSLL - Disallowance of deductions of goodwill generated in the acquisition of Cimentos Mauá   422,499   810,907
         
ICMS - SEFAZ/RJ  - Disallowance of the ICMS credits - Transfer of iron ore   779,093   731,416
         
ICMS - SEFAZ/RJ - Disallowance of credits on purchases of intermediate products   488,238   445,682
         
Disallowance of tax loss and negative calculation base resulting from adjustments in SAPLI - RFB   798,226   741,056
         
Infraction and Fine Imposition Notices (AIIM) - RFB - IRPJ/CSLL - Transfer Pricing   389,919   363,043
         
ICMS - SEFAZ/RJ - Transfer of imported raw material for a value lower than the TECAR import document   422,807   394,865
         
Notice of Violation and Imposition of Fine (AIIM) / Annulment Action - RFB - IRRF - Capital gain of CFM company sellers located abroad   338,273   317,522
         
Other tax lawsuits (federal, state, and municipal)   6,977,524   6,282,247
         
Social security lawsuits   647,801   288,973
         
Action to discuss the balance of the construction contract – Tebas   621,724   593,716
         
Action related to power supply payment’s charge - Light   492,535   440,002
         
Action that discusses Negotiation of energy sales - COPEN - CEEE-G   229,983   201,123
         
Collection of defaulted amounts of contracts for the execution of the Presidente Médici Thermoelectric Power Plant - SACE - CEEE-G (4)       205,262
         
Enforcement action applied by Brazilian antitrust authorities (CADE) (5)       122,136
         
Other civil lawsuits   1,620,259   1,423,591
         
Labor and social security lawsuits   2,580,452   2,091,666
         
Tax Execution Traffic Ticket Volta Grande IV   152,322   137,668
         
ACP Landfill Márcia I   306,389   306,389
         
Notice of IEF Commitment Agreement (6)   337,951    
         
Other environmental lawsuits   786,360   667,901
         
    48,454,570   53,651,946
         
(1) The Company succeeded in the appeals filed in Processes 19515.723039/2012-79 (CSN) and 19515.723053/2012-72 (CSN Mineração) which had as their objects the fines of 150% (Qualified Fine), closing the possible contingency of R$ 4,476,924 and R$ 993,756. The notifications of the decisions occurred on July 5 and 25, 2024, without the filing of appeals by the National Treasury. Thus, the respective write-offs of the processes were carried out on 07/2024. Finally, for the other processes related to the "Big Jump" theme, the prognoses remain the same (possible).

 

(2) The company was partially successful in Administrative Tax Proceeding 10600.720008/2020-32, in a CARF Ruling published on 09/11/2024, which recognized the unenforceability of WHT on capital gains of a legal entity resident in Japan, based on the rules of the treaty signed with the country. The application of the treaty was not the subject of a special appeal by the PGFN, making the company's partial success definitive. For the other installments of the tax assessment, the prognosis remains the same (possible).

 

(3) The company succeeded in Process 0000931-14.2011.8.19.0066, which disputed the requirement of ICMS, by the State of Rio de Janeiro, on credits arising from the acquisition of electric energy for industrialization, ending a contingency of R$ 185,116. The decision favorable to the company became final on 10/16/2024. The company also succeeded in Case 0000927-74.2011.8.19.0066, on the same subject, whose closure of the possible contingency of R$ 925,584 will be reflected in the results of the first quarter of 2025.

 

(4) In 2024, CEEE-G, a subsidiary of the Company, made a judicial agreement with SACE, which reduced the values disclosed as possible contingencies, now registered in other accounts payable, totaling R$ 43,371 as of December 31, 2024 (R$ 205,262 as of December 31, 2023).

 

(5) In November, CSN joined the "Desprola" program, launched by the Federal Government. The program consisted of paying all the Company's debts (4 concentration acts) to CADE with a 65% discount, where it made the upfront payment of R$ 34,000, ending discussions regarding the Steel Cartel process.

 

(6) In the 4th quarter of 2024, CSN Mineração was notified by the State Forest Institute of Minas Gerais, regarding the collection of a fine provided for in a Commitment Term signed by the Company with the said Agency in 2004. In said Notification, the aforementioned Agency is charging an amount of around R$ 337,000 for the alleged non-compliance with clauses of the instrument - which refers to compensation for environmental licensing from that time. Considering that CSN Mineração disagrees with the alleged breach of the mentioned Commitment Term and, consequently, with the respective fine collection - in addition to considering it disproportionate, a timely defense was presented in response to this notification, which will be forwarded for consideration by the Chamber for Prevention and Administrative Resolution of Conflicts of the Attorney General's Office of the State of Minas Gerais.