Investor Presentaiton
(b) Provision for tax, civil, labor, other contingencies, and outstanding judicial deposits
2021
Tax
Labor
Civil
Other
2020
Outstanding
judicial deposits
Outstanding
judicial deposits
Judicial deposits
Provision
Net amount
(i) Judicial deposits
Provision
Net amount
(i)
(123)
905
782
172
(123)
889
766
145
(120)
458
338
23
(123)
434
311
22
(18)
270
252
4
(17)
281
264
3
(1)
(262)
85
1,718
84
1,456
15
214
(1)
61
(264)
1,665
60
1,401
23
193
(i) The Company and its subsidiaries have balances deposited in lawsuits classified by Management, following the indications of the legal advisors of the Company and its subsidiaries as of
remote or possible loss, therefore, without the respective provision.
(c) Litigation in process with a likelihood of loss considered possible
The Company and its subsidiaries were party to litigations representing a risk
of possible losses, for which no provision has been made, as detailed below.
Nature
2021
2020
Compensation for exploration for mineral resources
(CFEM)
501
385
Collection of ICMS due to divergences regarding the
destination of the property
267
262
2021
2020
ICMS on electricity charges
234
226
Tax
Civil
12,311
12,581
IRPJ/CSLL - Transfer costs
195
191
Environmental
8,770
606
7,988
527
Error in fiscal classification - Importation
IRPJ/CSLL Deduction of expenses
191
186
7
78
Labor and social security
366
22,053
367
21,463
Other lawsuits
5,570
12,311
6,553
12,581
(c.1) Comments on contingent tax and public rights liabilities
with likelihood of loss considered possible
The following are the main contingent liabilities related to tax proceedings
in progress with the likelihood of possible loss, for which there is no provi-
sion recorded. In the table below we present an analysis of the relevance of
these processes:
Nature
Tax assessment notice - IRPJ/CSLL
IRPJ/CSLL Profits abroad
2021
1,784
2020
1,729
1,445
837
1,061
833
Disallowances of PIS/COFINS credits
709
692
Disallowance of IRPJ/CSLL negative balance
571
385
ICMS - Credit
(i) Tax assessment notice - IRPJ / CSLL
In December 2016, the subsidiary VCSA was assessed by the Brazilian
Federal Revenue Office in the historical amount of R$ 470 demanding the
collection of IRPJ and CSLL relating to the period of 2011, due to the al-
leged undue deduction of operating expenses and costs. In January 2018,
the VCSA became aware of the Lower Court decision from the Federal
Revenue's Judgment Office, which judged the appeal partially with grou-
nds, reducing the lawsuit by approximately R$ 114. In December 2018, the
Appeal of the Administrative Board of Tax Appeals was dismissed and the
Voluntary Appeal was partially accepted for the VCSA. At this moment we
await the formalization of the Court Decision. As at December 31, 2020,
171
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