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TAXATION | 12 Months Ended
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Jun. 30, 2022
TAXATION |
TAXATION | 9. TAXATION Tax reform in Argentina In December 2019, the Argentine Government promulgated Law 27,541. It provided that the tax rate reduction established by Law 27,430 (reduction of the income tax rate from 35% to 30% for fiscal periods beginning from January 1, 2018 until December 31, 2019, and 25% for fiscal periods beginning on or after January 1, 2020, inclusive) be suspended until the fiscal years beginning on or after January 1, 2021. Thus, the tax rate of 30% was maintained. Law 27,541 also provided that, for the first and second financial years starting on or after 1 January 2019, one-sixth of the inflation adjustment (provided by Law 27.420) will be computed in the fiscal year of the adjustment calculation and the remaining five-sixths in equal parts in the five tax periods immediately following. In June 2021, the Argentine Government approved a corporate income tax reform replacing the 30% fixed rate in force with a progressive tax rate. Depending on the amount of a corporation’s accumulated net taxable income, the reform could result in an increase or decrease in the corporate income tax rate. Under the progressive corporate income tax, a 25% tax rate will apply on net taxable income for accumulated net taxable income up to AR$5 million. For accumulated net taxable income from AR$5 million to AR$50 million, the progressive scale will apply a 30% tax rate. Finally, for accumulated net taxable income exceeding AR$50 million the progressive scale will apply a 35% tax rate. The reform also extends the 7% withholding tax on dividends for tax years beginning 1 January 2021 and thereafter. Given inflation that is expected in 2022, the Group has determined the income tax considering the application of the inflation adjustment for income tax in Argentina. The balances of income tax and minimum presumed income tax recoverable and payable are as follows: ​
​ | ​ | ​ | ​ | ​ | ​ | ​
​ |  | 06/30/2022 |  | 06/30/2021 |  | 06/30/2020
Current assets |  |  |  |  |  |
Income tax |  | 1,647,398 |  | 990,881 |  | 112,220
​ |  | 1,647,398 |  | 990,881 |  | 112,220
Non-current assets |  | ​ |  |  |  |
Income tax |  | 42,513 |  | 10,105 |  | 2,653
Minimum presumed income tax |  | 1,899 |  | 2,484 |  | 3,376
​ |  | 44,412 |  | 12,589 |  | 6,029
​
​ | ​ | ​ | ​ | ​ | ​ | ​
​ |  | 06/30/2022 |  | 06/30/2021 |  | 06/30/2020
Liabilities |  |  |  |  |  |
Income tax |  | 7,538,764 |  | 7,452,891 |  | 1,556,715
​ |  | 7,538,764 |  | 7,452,891 |  | 1,556,715
​ The roll forward of net deferred tax as of June 30, 2022, 2021 and 2020 is as follows: ​
​ | ​ | ​ | ​ | ​ | ​ | ​
​ |  | 06/30/2022 |  | 06/30/2021 |  | 06/30/2020
Beginning of the year deferred tax | ​ | (22,421,125) | ​ | (14,164,930) | ​ | (17,358,162)
Additions for business combination | ​ | — | ​ | (777,622) | ​ | —
Charge for the year | ​ | 1,031,836 | ​ | (4,257,912) | ​ | 1,888,006
Charge to OCI | ​ | 2,645,997 | ​ | (1,388,022) | ​ | (1,133,228)
Conversion difference | ​ | (6,251,277) | ​ | (1,832,639) | ​ | 2,438,454
Total net deferred tax | ​ | (24,994,569) | ​ | (22,421,125) | ​ | (14,164,930)
​ The roll forward of deferred tax assets and liabilities as of June 30, 2022, 2021 and 2020 are as follows: ​
​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​
​ |  | ​ |  | ​ |  | Transfer |  | ​ |  | ​ |  | ​
​ | ​ | ​ | ​ | ​ | ​ | from | ​ | ​ | ​ | ​ | ​ | ​
​ | ​ | ​ | ​ | Income | ​ | deferred | ​ | ​ | ​ | ​ | ​ | ​
​ | ​ | Balance | ​ | tax | ​ | tax | ​ | Charge | ​ | Conversion | ​ | Balance
Deferred tax assets | ​ | 06/30/2021 | ​ | provision | ​ | liabilities | ​ | to OCI | ​ | difference | ​ | 06/30/2022
Tax Loss-Carry Forward |  | 3,226,305 |  | (553,702) |  | — |  | — |  | 10,558 |  | 2,683,161
Changes in fair value of financial assets or liabilities |  | 89,574 |  | 2,917 |  | — |  | — |  | 20,538 |  | 113,029
Trade receivables |  | 609,913 |  | (670,808) |  | — |  | — |  | 152,499 |  | 91,604
Allowances |  | — |  | — |  | 654,260 |  | — |  | — |  | 654,260
Royalties |  | 485,426 |  | (83,220) |  | — |  | — |  | 122,851 |  | 525,057
Others |  | 1,552,370 |  | 659,511 |  | — |  | — |  | 288,337 |  | 2,500,218
Total deferred tax assets |  | 5,963,588 |  | (645,302) |  | 654,260 |  | — |  | 594,783 |  | 6,567,329
​
​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​
​ |  | ​ |  | ​ |  | Transfer |  | ​ |  | ​ |  | ​
​ | ​ | ​ | ​ | ​ | ​ | from | ​ | ​ | ​ | ​ | ​ | ​
​ | ​ | Balance | ​ | Income tax | ​ | deferred tax | ​ | Charge to | ​ | Conversion | ​ | Balance
​ | ​ | 06/30/2021 | ​ | provision | ​ | assets | ​ | OCI | ​ | difference | ​ | 06/30/2022
Intangible assets |  | (10,624,621) |  | (599,428) |  | — |  | — |  | (2,440,650) |  | (13,664,699)
Property, plant and equipment |  | (12,632,296) |  | (1,149,988) |  | — |  | 2,645,997 |  | (3,054,273) |  | (14,190,560)
Inflation tax adjustment |  | (2,682,172) |  | 1,744,722 |  | — |  | — |  | (670,462) |  | (1,607,912)
Allowances |  | (78,076) |  | 687,155 |  | (654,260) |  | — |  | 45,181 |  | —
Inventories |  | (1,821,524) |  | 872,120 |  | — |  | — |  | (588,906) |  | (1,538,310)
Biological assets |  | (229,296) |  | 287,329 |  | — |  | — |  | (58,033) |  | —
Goverment grants |  | (3,179) |  | 1,768 |  | — |  | — |  | (804) |  | (2,215)
Others financial assets |  | (276,800) |  | (55,050) |  | — |  | — |  | (70,540) |  | (402,390)
Right-of-use leased asset |  | (32,651) |  | (73,770) |  | — |  | — |  | (7,573) |  | (113,994)
Others |  | (4,098) |  | (37,720) |  | — |  | — |  | — |  | (41,818)
Total deferred tax liabilities |  | (28,384,713) |  | 1,677,138 |  | (654,260) |  | 2,645,997 |  | (6,846,060) |  | (31,561,898)
​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​
Net deferred tax |  | (22,421,125) |  | 1,031,836 |  | — |  | 2,645,997 |  | (6,251,277) |  | (24,994,569)
​
​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​
​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | Transfer | ​ | ​ | ​ | ​ | ​ | ​
​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | from | ​ | ​ | ​ | ​ | ​ | ​
​ | ​ | ​ | ​ | Additions | ​ | Income | ​ | deferred | ​ | ​ | ​ | ​ | ​ | ​
​ | ​ | Balance | ​ | for business | ​ | tax | ​ | tax | ​ | Charge | ​ | Conversion | ​ | Balance
Deferred tax assets |  | 06/30/2020 |  | combination |  | provision |  | liabilities |  | to OCI |  | difference |  | 06/30/2021
Tax Loss-Carry Forward |  | 2,362,657 |  | — |  | 982,329 |  | — |  | — |  | (118,681) |  | 3,226,305
Changes in fair value of financial assets or liabilities |  | 41,183 |  | — |  | 51,037 |  | — |  | — |  | (2,646) |  | 89,574
Trade receivables |  | 1,068,054 |  | — |  | 138,438 |  | — |  | — |  | (596,579) |  | 609,913
Royalties | ​ | 245,140 | ​ | — | ​ | 214,493 | ​ | — | ​ | — | ​ | 25,793 | ​ | 485,426
Right-of-use leased asset | ​ | 5,424 | ​ | — | ​ | (38,793) | ​ | 32,651 | ​ | — | ​ | 718 | ​ | —
Others |  | 813,294 |  | 370,556 |  | (427,433) |  | — |  | — |  | 795,953 |  | 1,552,370
Total deferred tax assets |  | 4,535,752 |  | 370,556 |  | 920,071 |  | 32,651 |  | — |  | 104,558 |  | 5,963,588
​
​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​
​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | Transfer | ​ | ​ | ​ | ​ | ​ | ​
​ | ​ | ​ |  | ​ |  | ​ |  | from |  | ​ |  | ​ |  | ​
​ | ​ | ​ |  | Additions |  | Income |  | deferred |  | ​ | ​ | ​ | ​ | ​
​ | ​ | Balance |  | for business | ​ | tax | ​ | tax |  | Charge | ​ | Conversion | ​ | Balance
Deferred tax liabilities |  | 06/30/2020 |  | combination |  | provision |  | assets |  | to OCI |  | difference |  | 06/30/2021
Intangible assets |  | (6,839,112) |  | (882,434) |  | (2,188,663) |  | — |  | — |  | (714,412) |  | (10,624,621)
Property, plant and equipment |  | (9,365,882) |  | (537,922) |  | (357,614) |  | — |  | (1,388,022) |  | (982,856) |  | (12,632,296)
Borrowings |  | (7,930) |  | — |  | 8,797 |  | — |  | — |  | (867) |  | —
Inflation tax adjustment |  | (2,032,078) |  | 73,755 |  | (527,654) |  | — |  | — |  | (196,195) |  | (2,682,172)
Allowances | ​ | (209,490) | ​ | 201,969 | ​ | (46,622) | ​ | — | ​ | — | ​ | (23,933) | ​ | (78,076)
Inventories | ​ | (237,258) | ​ | (3,546) | ​ | (1,561,687) | ​ | — | ​ | — | ​ | (19,033) | ​ | (1,821,524)
Biological assets | ​ | — | ​ | — | ​ | (229,296) | ​ | — | ​ | — | ​ | — | ​ | (229,296)
Government grants | ​ | (3,939) | ​ | — | ​ | 1,174 | ​ | — | ​ | — | ​ | (414) | ​ | (3,179)
Others financial assets | ​ | — | ​ | — | ​ | (277,841) | ​ | — | ​ | — | ​ | 1,041 | ​ | (276,800)
Right-of-use leased asset | ​ | — | ​ | — | ​ | — | ​ | (32,651) | ​ | — | ​ | — | ​ | (32,651)
Others |  | (4,993) |  | — |  | 1,423 |  | — |  | — |  | (528) |  | (4,098)
Total deferred tax liabilities |  | (18,700,682) |  | (1,148,178) |  | (5,177,983) |  | (32,651) |  | (1,388,022) |  | (1,937,197) |  | (28,384,713)
​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​
Net deferred tax |  | (14,164,930) |  | (777,622) |  | (4,257,912) |  | — |  | (1,388,022) |  | (1,832,639) |  | (22,421,125)
​
​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​
​ | ​ | ​ | ​ | ​ | ​ | Transfer | ​ | ​ | ​ | ​ | ​ | ​
​ | ​ | ​ | ​ | ​ | ​ | from | ​ | ​ | ​ | ​ | ​ | ​
​ | ​ | ​ | ​ | Income | ​ | deferred | ​ | ​ | ​ | ​ | ​ | ​
​ | ​ | Balance | ​ | tax | ​ | tax | ​ | Charge | ​ | Conversion | ​ | Balance
Deferred tax assets |  | 06/30/2019 |  | provision |  | liabilities |  | to OCI |  | difference |  | 06/30/2020
Tax Loss-Carry Forward |  | 2,663,813 |  | (133,346) |  | — |  | — |  | (167,810) |  | 2,362,657
Changes in fair value of financial assets or liabilities |  | 32,062 |  | 20,222 |  | — |  | — |  | (11,101) |  | 41,183
Trade receivables |  | 374,425 |  | 764,707 |  | — |  | — |  | (71,078) |  | 1,068,054
Goverment grants |  | 2,649 |  | (6,216) |  | 3,939 |  | — |  | (372) |  | —
Royalties | ​ | — | ​ | 245,140 | ​ | — | ​ | — | ​ | — | ​ | 245,140
Right-of-use leased asset | ​ | — | ​ | 5,676 | ​ | — | ​ | — | ​ | (252) | ​ | 5,424
Others |  | 670,760 |  | 263,407 |  | — |  | — |  | (120,873) |  | 813,294
Total deferred tax assets |  | 3,743,709 |  | 1,159,590 |  | 3,939 |  | — |  | (371,486) |  | 4,535,752
​
​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​
​ | ​ | ​ | ​ | ​ | ​ | Transfer | ​ | ​ | ​ | ​ | ​ | ​
​ | ​ | ​ |  | ​ |  | from |  | ​ |  | ​ |  | ​
​ | ​ | ​ |  | Income |  | deferred | ​ | ​ | ​ | ​ | ​ | ​
​ | ​ | Balance |  | tax |  | tax | ​ | Charge | ​ | Conversion | ​ | Balance
Deferred tax liabilities |  | 06/30/2019 |  | provision |  | assets |  | to OCI |  | difference |  | 06/30/2020
Intangible assets |  | (9,458,239) |  | 1,469,311 |  | — |  | — |  | 1,149,816 |  | (6,839,112)
Property, plant and equipment |  | (9,618,648) |  | 45,028 |  | — |  | (1,133,228) |  | 1,340,966 |  | (9,365,882)
Borrowings |  | (13,170) |  | 3,548 |  | — |  | — |  | 1,692 |  | (7,930)
Inflation tax adjustment |  | (1,706,092) |  | (589,811) |  | — |  | — |  | 263,825 |  | (2,032,078)
Allowances | ​ | (152,159) | ​ | (84,515) | ​ | — | ​ | — | ​ | 27,184 | ​ | (209,490)
Inventories | ​ | (153,563) | ​ | (110,152) | ​ | — | ​ | — | ​ | 26,457 | ​ | (237,258)
Goverment grants | ​ | — | ​ | — | ​ | (3,939) | ​ | — | ​ | — | ​ | (3,939)
Others |  | — |  | (4,993) |  | — |  | — |  | — |  | (4,993)
Total deferred tax liabilities |  | (21,101,871) |  | 728,416 |  | (3,939) |  | (1,133,228) |  | 2,809,940 |  | (18,700,682)
​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​
Net deferred tax | ​ | (17,358,162) | ​ | 1,888,006 | ​ | — | ​ | (1,133,228) | ​ | 2,438,454 | ​ | (14,164,930)
​ The following table provides a reconciliation of the statutory tax rate to the effective tax rate. As the operations of the Group’s Argentine subsidiaries are the most significant source of profit or loss before tax, the following reconciliation has been prepared using the Argentine statutory tax rate: ​
​ | ​ | ​ | ​ | ​ | ​ | ​
​ |  | 06/30/2022 |  | 06/30/2021 |  | 06/30/2020
Earning before income tax-rate | ​ | 14,063,630 | ​ | 10,530,548 | ​ | 6,443,338
Income tax expense by applying tax rate in force in the respective countries |  | (9,166,026) |  | (8,481,737) | ​ | (1,919,981)
Share of profit or loss of subsidiaries, joint ventures and associates |  | 440,944 |  | 274,877 | ​ | 847,512
Stock options charge |  | (50,163) |  | (58,248) | ​ | (298,222)
Rate change adjustment |  | — |  | (1,780,962) | ​ | (144,660)
Non-deductible expenses |  | (303,518) |  | (365,350) | ​ | (84,128)
Untaxed gains | ​ | — | ​ | 557,911 | ​ | —
Representation expenses |  | — |  | — | ​ | (36,691)
Foreign investment coverage |  | 510,487 |  | 390,170 | ​ | 551,968
Tax inflation adjustment | ​ | 1,826,488 | ​ | (2,182,988) | ​ | (1,174,964)
Result of inflation effect on monetary items and other finance results | ​ | (10,669,710) | ​ | (3,181,733) | ​ | (255,488)
Others | ​ | (561,036) | ​ | 476,890 | ​ | 307,944
Income tax expenses |  | (17,972,534) |  | (14,351,170) | ​ | (2,206,710)
​ The Group did not recognize deferred income tax liabilities of $3,466,195, $2,497,033 and $1,052,022, as of June 30, 2022, 2021 and 2020, respectively, related to their investments in foreign subsidiaries, associates and joint ventures. In addition, the withholdings and/or similar taxes paid at source may be creditable against the Group’s potential final tax liability. Principal statutory taxes rates in the countries where the Group operates for all of the years presented are: ​
​ | ​ | ​ | ​ | ​ | ​ | ​ | ​
​ | ​ | Income tax rate |
Tax jurisdiction |  | 2022 |  | 2021 |  | 2020 |
Argentina |  | 25% - 35 | % | 30 | % | 30 | %
Cayman Island |  | 0 | % | 0 | % | 0 | %
Paraguay | ​ | 10 | % | 10 | % | 10 | %
Uruguay | ​ | 25 | % | 25 | % | 25 | %
France | ​ | 25 | % | 26.5 | % | 28 | %
Brazil | ​ | 34 | % | 34 | % | 34 | %
United States of America |  | 21 | % | 21 | % | 21 | %
​
​ | ​ | ​ | ​ | ​ | ​ | ​
​ |  | 06/30/2022 |  | 06/30/2021 |  | 06/30/2020
Current tax expense |  | (19,004,370) |  | (10,093,258) |  | (4,094,716)
Deferred tax |  | 1,031,836 | ​ | (4,257,912) |  | 1,888,006
Total |  | (17,972,534) |  | (14,351,170) |  | (2,206,710)
​ The charge for income tax charged directly to profit or loss and the amount and expiry date of carry forward tax losses as of June 30, 2022 are as follows: ​
​ | ​ | ​ | ​ | ​ | ​ | ​ | ​ | ​
Fiscal year |  | Tax-Loss Carry forward |  | Tax-Loss Carry forward |  | Prescription |  | Tax jurisdiction
2018 |  | 155,328 |  | 44,758 |  | 2023 |  | Argentina
2019 |  | 126,138 |  | 31,535 |  | 2024 |  | Argentina
2020 |  | 813,278 |  | 203,320 |  | 2025 |  | Argentina
2020 |  | 223,999 |  | 47,040 |  | 2040 |  | United States of America
2021 | ​ | 4,135,303 | ​ | 1,197,750 | ​ | 2026 | ​ | Argentina
2021 |  | 511,839 |  | 107,486 |  | 2041 |  | United States of America
2022 |  | 2,980,889 |  | 826,118 |  | 2027 |  | Argentina
2022 |  | 1,072,159 |  | 225,154 |  | 2042 |  | United States of America
Total |  | 10,018,933 |  | 2,683,161 |  |  |  |
​ The amount of tax losses for the fiscal year ended on June 30, 2022 is an estimate of the amount to be presented in the tax return. The amount and expiry date of unused tax credits of Argentina minimum presumed income tax as of June 30, 2022 is as follows: ​
​ | ​ | ​ | ​ | ​
Fiscal year |  | Amount |  | Prescription
2014 |  | 362 |  | 2024
2015 |  | 767 |  | 2025
2016 |  | 770 |  | 2026
Total |  | 1,899 |  |
​ Estimates There is an inherent material uncertainty related to management’s estimation of the ability of the Group to use the deferred tax assets (both carryforward of unused tax losses and deductible temporary differences) and the credit of minimum presumed income tax because their future utilization depends on the generation of enough future taxable income by the entities within the Group during the periods in which those temporary differences are deductible or when the unused tax losses can be used. Based on the projections of future taxable income for the periods in which the deferred tax assets are deductible, the Group’s management estimates that, except for the part of deferred tax asset that were unrecognized, it is probable that the entities within the Group can utilize those deferred tax assets, which depends, among other factors, on the success of the current projects of agricultural biotechnology, the future market price of commodities and the market share of the entities within the Group. The estimates of management about the demonstrability of the recognition criteria for these deferred tax assets and their subsequent recoverability represent the best estimate that can be made based on all the available evidence, existing facts and circumstances and the use of reasonable and supportable assumptions in the projections of future taxable income. Therefore, the Consolidated financial statements do not include adjustments that could result if the entities within the Group would not be able to recover the deferred tax assets through the generation of enough future taxable income.

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