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Taxation

12 Months Ended

Jun. 30, 2025

TAXATION

The balances of deferred tax assets and liabilities are as follows:

	06/30/2025			06/30/2024
Deferred tax assets
Tax Loss-Carry Forward		-			26,988,067
Others financial assets		-			813,780
Others		-			2,516,719
Royalties		-			764,888
Trade receivables		-			532,106
Allowances		-			942,587
Government grants		-			15,090
Total deferred tax assets		-			32,573,237

Deferred tax liabilities
Intangible assets		(15,767,275	)		(28,444,095	)
Property, plant and equipment depreciation		-			(14,608,912	)
Inventories		-			(8,041,220	)
Others financial assets		-			(464,404	)
Right-of-use leased asset		-			(190,088	)
Inflation tax adjustment		-			(302,456	)
Others		-			(546,277	)
Total deferred tax liabilities		(15,767,275	)		(52,597,452	)

Net deferred tax		(15,767,275	)		(20,024,215	)

The roll forward of deferred tax assets and liabilities as of June 30, 2025 and 2024 are as follows:

	Balance 06/30/2024			Business combination / (loss) of control			Income tax provision			Conversion difference			Balance 06/30/2025
Deferred tax assets
Tax Loss-Carry Forward		26,988,067			(21,525,926	)		(5,579,828	)		117,687			-
Others financial assets		813,780			(475,554	)		(342,341	)		4,115			-
Trade receivables		532,106			(1,353,889	)		822,145			(362	)		-
Royalties		764,888			(744,388	)		(18,311	)		(2,189	)		-
Allowances		942,587			(1,053,605	)		98,032			12,986			-
Government grants		15,090			-			(15,596	)		506			-
Others		2,516,719			227,950			(2,744,669	)		-			-
Total deferred tax assets		32,573,237			(24,925,412	)		(7,780,568	)		132,743			-

Deferred tax liabilities
Intangible assets		(28,444,095	)		12,428,299			214,190			34,331			(15,767,275	)
Property, plant and equipment depreciation		(14,608,912	)		15,315,097			(703,102	)		(3,083	)		-
Inventories		(8,041,220	)		6,611,790			1,429,430			-			-
Biological assets		-			640,035			(640,035	)		-			-
Others financial assets		(464,404	)		28,040			436,364			-			-
Right-of-use leased asset		(190,088	)		180,967			10,505			(1,384	)		-
Inflation tax adjustment		(302,456	)		26,801			218,362			57,293			-
Others		(546,277	)		541,800			178,733			(174,256	)		-
Total deferred tax liabilities		(52,597,452	)		35,772,829			1,144,447			(87,099	)		(15,767,275	)

Net deferred tax		(20,024,215	)		10,847,417			(6,636,121	)		45,644			(15,767,275	)

Deferred tax assets	Balance 06/30/2023			Business combination / (loss) of control			Income tax provision			Conversion difference			Charge to OCI			Balance 06/30/2024
Tax Loss-Carry Forward		21,215,789			(62,585	)		7,752,424			(694,718	)		(1,222,843	)		26,988,067
Others financial assets		1,336,260			(2,299	)		(423,116	)		(97,065	)		-			813,780
Trade receivables		447,449			-			214,734			(130,077	)		-			532,106
Royalties		723,082			-			48,310			(6,504	)		-			764,888
Allowances		1,213,899			-			(221,106	)		(50,206	)		-			942,587
Government grants		93,996			(39,261	)		(42,199	)		2,554			-			15,090
Others		3,402,846			765,384			(1,651,511	)		-			-			2,516,719
Total deferred tax assets		28,433,321			661,239			5,677,536			(976,016	)		(1,222,843	)		32,573,237

Deferred tax liabilities
Intangible assets		(29,117,986	)		(301,659	)		867,636			107,914			-			(28,444,095	)
Property, plant and equipment depreciation		(13,678,341	)		(174,228	)		(773,812	)		17,469			-			(14,608,912	)
Inventories		(6,461,576	)		(939,250	)		(640,394	)		-			-			(8,041,220	)
Others financial assets		(2,154,504	)		-			1,690,100			-			-			(464,404	)
Right-of-use leased asset		(120,442	)		(115,495	)		30,998			14,851			-			(190,088	)
Inflation tax adjustment		(1,131,895	)		10,732			827,211			(8,504	)		-			(302,456	)
Others		(607,722	)		-			111,773			(50,328	)		-			(546,277	)
Total deferred tax liabilities		(53,272,466	)		(1,519,900	)		2,113,512			81,402			-			(52,597,452	)

Net deferred tax		(24,839,145	)		(858,661	)		7,791,048			(894,614	)		(1,222,843	)		(20,024,215	)

The tax on the Group’s profit before tax differs from the theoretical amount that would arise using the weighted average tax rate applicable to profits of the consolidated entities as follows:

	06/30/2025			06/30/2024			06/30/2023
(Loss) / earnings before income tax-rate		(170,003,479	)		(27,958,152	)		50,794,242
Income tax expense by applying tax rate in force in the respective countries		45,342,071			7,224,973			(7,628,367	)
Share of profit or loss of subsidiaries, joint ventures and associates		(8,232,869	)		(5,141,460	)		12,645,224
Puttable instruments charge		-			-			(3,645	)
Stock options charge		(167,601	)		(1,366,999	)		(586,774	)
Derecognition of deferred tax assets (i)		(40,565,962	)		(94,189	)		428,530
Mutual funds adjustments		18,471			27,560			-
Non-deductible expenses		(4,027,734	)		(1,469,872	)		(373,655	)
Result of inflation effect on monetary items and other finance results		335,680			(5,113,890	)		(7,872,801	)
Tax inflation adjustment		1,633,659			4,278,344			5,916,143
Rate change adjustment		-			118,060			(192,127	)
Others		(971,836	)		434,321			(4,162	)
Income tax expenses		(6,636,121	)		(1,103,152	)		2,328,366

(i)	Mainly represent derecognition of deferred tax assets from Bioceres S.A. because it initiated the voluntary bankruptcy proceeding (Note 21).

	06/30/2025			06/30/2024			06/30/2023
Current tax expense		-			(8,894,200	)		(1,311,506	)
Deferred tax		(6,636,121	)		7,791,048			3,639,872
		(6,636,121	)		(1,103,152	)		2,328,366

The income tax expense was calculated by applying the tax rate in force in the respective countries, as follows:

Tax jurisdiction	Earnings before income tax-rate			Weight average applicable tax rate			Income tax as of June 30, 2025
Low or null taxation jurisdictions		(7,247,084	)		0.0	%		-
Loss-making entities		(162,756,395	)		27.9	%		45,342,071
		(170,003,479	)					45,342,071

Tax jurisdiction	Earnings before income tax-rate			Weight average applicable tax rate			Income tax as of June 30, 2024
Low or null taxation jurisdictions		13,131,953			0.0	%		-
Profit-making entities		32,251,706			32.2	%		(10,370,389	)
Loss-making entities		(73,341,811	)		24.0	%		17,595,362
		(27,958,152	)					7,224,973

Tax jurisdiction	Earnings before income tax-rate			Weight average applicable tax rate			Income tax as of June 30, 2023
Low or null taxation jurisdictions		30,921,548			0.0	%		-
Profit-making entities		73,999,737			21.5	%		(15,899,829	)
Loss-making entities		(54,127,043	)		15.3	%		8,271,462
		50,794,242						(7,628,367	)

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 it is not probable that the entities within the Group can utilize those deferred tax assets. Tax-loss Carry unrecognized as of June 30, 2025 amounting to $7.6 million.