| DEFERRED INCOME TAX AND SOCIAL CONTRIBUTION |
| 17. |
DEFERRED INCOME TAX AND SOCIAL CONTRIBUTION |
Deferred taxes for income tax and social contribution
taxes are calculated on temporary differences between the tax bases of these taxes and the accounting calculations of the Company, which
include tax losses. The tax rates in Brazil, which are expected to be applicable upon the realization of the deferred taxes, are 25% for
income tax and 9% for social contribution. For other regions in which the Company operates, the expected nominal rates are as follows:
| Schedule of expected nominal rates |
|
| Central America and the Caribbean |
from 15% to 27% |
| Latin America - South (i) |
from 10% to 35% |
| Canada |
26.5% |
| Luxembourg |
24.94% |
| (i) |
Amendments to Argentine tax legislation enacted in June 2021 and applicable from January 2021 increased the income tax rate from 30%
to 35%. |
Deferred tax assets are recognized to the extent that
it is probable that future taxable profits are probable, which may be offset against recorded temporary differences at December 31, 2022.
The details of the amount of deferred income tax and social contribution
by type of temporary difference are as follows:
| Schedule of deferred income tax |
|
|
|
|
|
|
|
| |
2022 |
|
2021 |
| |
Assets |
Liabilities |
Net |
|
Assets |
Liabilities |
Net |
| Investment securities |
7.5 |
- |
7.5 |
|
12.5 |
(2.5) |
10.0 |
| Intangible |
- |
(1,690.2) |
(1,690.2) |
|
- |
(1,634.5) |
(1,634.5) |
| Employee benefits |
951.2 |
- |
951.2 |
|
1,278.2 |
(2.0) |
1,276.2 |
| Trade payables |
3,232.8 |
(2.9) |
3,229.9 |
|
4,113.3 |
(1.1) |
4,112.2 |
| Trade receivables |
38.6 |
(3.8) |
34.8 |
|
50.6 |
- |
50.6 |
| Derivatives |
95.1 |
(44.8) |
50.3 |
|
232.2 |
(72.4) |
159.8 |
| Interest-Bearing Loans and Borrowings |
0.5 |
(0.9) |
(0.4) |
|
- |
(1.6) |
(1.6) |
| Inventories |
413.9 |
(139.3) |
274.6 |
|
328.2 |
(49.1) |
279.1 |
| Property, plant and equipment |
899.5 |
(2,177.1) |
(1,277.6) |
|
645.4 |
(2,027.0) |
(1,381.6) |
| Withholding tax on undistributed profits and royalties |
- |
(1,877.6) |
(1,877.6) |
|
- |
(2,079.5) |
(2,079.5) |
| Investments in joint ventures |
- |
(421.6) |
(421.6) |
|
- |
(421.6) |
(421.6) |
| Losses carried forward |
2,660.7 |
- |
2,660.7 |
|
1,298.8 |
- |
1,298.8 |
| Provisions |
819.3 |
- |
819.3 |
|
696.9 |
(0.2) |
696.7 |
| Impact of the adoption of IFRS 16 (Leases) |
35.1 |
(11.4) |
23.7 |
|
78.6 |
(0.3) |
78.3 |
| ICMS on the assessment bases of PIS/COFINS |
- |
(168.2) |
(168.2) |
|
- |
(1,019.6) |
(1,019.6) |
| Other items |
260.8 |
(164.1) |
96.7 |
|
110.3 |
(19.9) |
90.4 |
| Gross deferred tax assets/(liabilities) |
9,415.0 |
(6,701.9) |
2,713.1 |
|
8,845.0 |
(7,331.3) |
1,513.7 |
| Netting by taxable entity |
(2,976.2) |
2,976.2 |
- |
|
(4,117.3) |
4,117.3 |
- |
| Net deferred tax assets/(liabilities) |
6,438.8 |
(3,725.7) |
2,713.1 |
|
4,727.7 |
(3,214.0) |
1,513.7 |
The Company only reclassifies the balances of
deferred income tax and social contribution assets against liabilities to a net presentation basis when the applicable compensation criteria
are met.
The critical estimates of Ambev’s Management, as well
the main contingent liabilities related to uncertainty about the tax treatment of income, are disclosed in Notes 3 (i) and 30, respectively.
As at December 31, 2022 the deferred tax assets and liabilities
related to combined tax losses which are expected to be utilized or settled using temporary differences, as follows:
| Schedule of deferred tax assets and liabilities |
|
|
|
| |
2022 |
| Deferred taxes not related to tax losses |
to be realized within 12 months |
to be realized after 12 months |
Total |
| |
| Investment securities |
- |
7.5 |
7.5 |
| Intangible |
(1.3) |
(1,688.9) |
(1,690.2) |
| Employee benefits |
230.8 |
720.4 |
951.2 |
| Trade payables |
(209.4) |
3,439.3 |
3,229.9 |
| Trade receivables |
25.8 |
9.0 |
34.8 |
| Derivatives |
(199.9) |
250.2 |
50.3 |
| Interest-bearing loans and borrowings |
(0.6) |
0.2 |
(0.4) |
| Inventories |
403.3 |
(128.7) |
274.6 |
| Property, plant and equipment |
51.7 |
(1,329.3) |
(1,277.6) |
| Withholding tax on undistributed profits and royalties |
(172.7) |
(1,704.9) |
(1,877.6) |
| Investments in joint ventures |
- |
(421.6) |
(421.6) |
| Provisions |
465.2 |
354.1 |
819.3 |
| Impact of the adoption of IFRS 16 (Leases) |
- |
23.7 |
23.7 |
| ICMS on the assessment bases of PIS/COFINS |
- |
(168.2) |
(168.2) |
| Other items |
29.0 |
67.7 |
96.7 |
| Total |
621.9 |
(569.5) |
52.4 |
The majority of tax losses and negative social contribution
bases on which deferred income tax and social contribution were calculated do not have a statute of limitations. The use of credits related
to tax losses is based on the projected future existence of taxable profits, limited to 30% of taxable income for the year, according
to the actual figures for prior years, and the projections of the Company's business in the economies in which they are located, and thus
is in compliance with the applicable fiscal and accounting rules.
Schedule of deferred tax realization related to tax losses
|
|
| Deferred tax related to tax losses |
2022 |
| 2023 |
256.9 |
| 2024 |
168.7 |
| 2025 |
102.9 |
| 2026 |
106.6 |
| 2027 |
1,146.6 |
| 2028 a 2030 |
799.5 |
| 2031 a 2032 (i) |
79.5 |
| Total |
2,660.7 |
| (i) |
There is no expectation of realization beyond a term of ten years. |
As at December 31, 2022, the tax credits related to
accumulated tax losses in the amount of R$875.3
(R$1,055.6
in 2021) were not recorded, as realization is not probable.
A significant portion of the deferred tax asset related
to tax losses amount does not have any limits on carrying forward or utilization, and the tax losses carried forward in relation to credit
are equivalent to R$3,359.5 in 2022 (R$4,122.5 in 2021).
The net change in deferred income tax and social contribution
is as follows:
| Schedule of net change in deferred income tax and social contribution |
|
| At December 31, 2020 |
1,517.4 |
| Recognition of actuarial gains/(losses) |
(116.6) |
| Investment hedge – put option granted on subsidiaries |
(99.7) |
| Cash flow hedge – gains/(losses) |
(239.9) |
| Gains/(losses) on translation of other foreign operations |
398.0 |
| Recognized in other comprehensive income |
(58.2) |
| Recognized in the income statement |
632.0 |
| Changes directly in the balance sheet |
(577.5) |
| Recognized in deferred tax |
(256.1) |
| Effect of application of IAS 29 (hyperinflation) |
(256.1) |
| Recognized in other balance sheet group |
(321.4) |
| At December 31, 2021 |
1,513.7 |
| Recognition of actuarial gains/(losses) |
(146.9) |
| Investment hedge – put option granted on subsidiaries |
(105.0) |
| Cash flow hedge – gains/(losses) |
41.3 |
| Gains/(losses) on translation of other foreign operations |
(419.3) |
| Recognized in other comprehensive income |
(629.9) |
| Recognized in the income statement |
2,374.5 |
| Changes directly in the balance sheet |
(545.2) |
| Recognized in deferred tax |
(595.5) |
| Effect of application of IAS 29 (hyperinflation) |
(595.5) |
| Recognized in other balance sheet group |
50.3 |
| At December 31, 2022 |
2,713.1 |
|