| Tax assets and liabilities |
| 23. | Tax assets and liabilities |
a) Income tax and social contribution
The total charges for the period can be reconciled
with the accounting profit as follows:
| Schedule of total charge for the period can be reconciled to accounting profit |
|
|
|
| Thousand of Reais |
2025 |
2024 |
2023 |
| |
|
|
|
| Operating Profit Before Tax |
16,728,994 |
19,190,228 |
11,921,651 |
| Tax Rate (25% income tax and 20% social contribution tax) (3) |
(7,528,047) |
(8,635,601) |
(5,364,743) |
| PIS and COFINS (net of income and social contribution taxes) (1) |
(4,605,498) |
(3,258,281) |
(3,789,866) |
| Non-taxable/Non-deductible: |
|
|
|
| Equity method |
206,241 |
140,870 |
108,380 |
| Non-Deductible Expenses Net from Non-Taxable Income (2) |
1,911,762 |
1,345,411 |
1,016,111 |
| Adjustments: |
|
|
|
| Recognition (Reversal) of Income/Social Contribution Taxes on Temporary Differences |
193,371 |
(224,038) |
127,166 |
| Interest on Equity |
3,376,308 |
2,589,128 |
2,660,040 |
| Effect of CSLL (Social Contribution on Net Profit) Rate Difference (3) |
970,695 |
1,441,329 |
684,133 |
| Other adjustments |
1,711,297 |
824,718 |
2,135,940 |
| Income taxes |
(3,763,871) |
(5,776,465) |
(2,422,839) |
| Comprising: |
|
|
|
| Current taxes |
(8,068,996) |
(6,193,804) |
(7,962,995) |
| Deferred taxes |
4,305,125 |
417,339 |
5,540,156 |
| Taxes paid during the fiscal year |
(6,509,969) |
(5,423,514) |
(5,892,511) |
| (1) |
PIS and COFINS are considered as components of the profit base (net base of certain income and expenses); therefore, in accordance with
IAS 12, they are recorded as income taxes. |
| (2) |
It mainly includes the tax effect on income from updates to judicial deposits and other income and expenses that are permanent differences. |
| (3) |
In the Consolidated Financial Statements, we account for the difference in CSLL (Social Contribution on Net Profit) tax rates of 9% (non-financial
companies), 15% (financial companies), and 20% (banks). |
Foreign Exchange Hedge of the Grand Cayman and Luxembourg
Branches
Banco Santander operates branches in the Cayman Islands
and Luxembourg, which are primarily used for raising funds in international capital and financial markets, providing the Bank with credit
lines that are extended to its clients for trade financing and working capital.
To hedge against exchange rate fluctuations, the Bank
uses derivatives and funding. According to Brazilian tax rules, gains or losses resulting from the impact of the Real's appreciation or
depreciation on foreign investments are taxable or deductible for income tax/social contribution purposes, while gains or losses from
derivatives used as hedging are also taxable or deductible. The purpose of these derivatives is to protect net income after taxes.
The still distinct tax treatment for PIS and COFINS
taxes on such exchange rate differences results in volatility in "Operating Profit before Tax" and in the "Income Tax"
item. The effects of the transactions carried out, as well as the total effect of the exchange rate hedge for the fiscal years ending
December 31, 2025, 2024, and 2023, are detailed below:
| Schedule of foreign exchange hedge |
|
|
|
| Thousand of Reais |
2025 |
2024 |
2023 |
| Foreign exchange fluctuations (net) |
|
|
|
| Gains (losses) arising from exchange rate fluctuations on the Bank’s investments in the Cayman and Luxembourg Branches |
(7,474,761) |
13,627,778 |
(3,281,452) |
| Gains (losses) on financial assets and liabilities |
|
|
|
| Income generated from the use of derivative contracts as foreign exchange hedge |
7,838,473 |
(14,292,394) |
3,444,617 |
| Income Taxes |
|
|
|
| Tax effect of derivative contracts used as hedge - PIS/COFINS |
(363,712) |
664,616 |
(163,165) |
b) Effective tax rate calculation
The effective tax rates are:
| Schedule of effective tax rate |
|
|
|
| Thousand of Reais |
2025 |
2024 |
2023 |
| Operating Income Before Tax |
16,728,994 |
19,190,228 |
11,921,651 |
| Income Tax |
(3,763,871) |
(5,776,465) |
(2,422,839) |
| Effective tax rate |
22.50% |
30.10% |
20.32% |
c) Tax recognized in equity
In addition to the income tax recognized in the consolidated
income statement, the Bank has recorded the following amounts directly in equity:
| Schedule of bank recorded amounts in equity |
|
|
|
| Thousand of Reais |
2025 |
2024 |
2023 |
| Tax credits recognized in equity |
315,477,464 |
339,389,357 |
139,356,609 |
| Measurement of securities at fair value through other comprehensive income |
308,792,800 |
333,401,042 |
136,550,936 |
| Measurement of cash flow hedge |
3,032,990 |
2,607,676 |
223,487 |
| Measurement of investment hedge |
1,421,361 |
562,353 |
562,353 |
| Measurement of defined benefit plan |
2,230,313 |
2,818,286 |
2,019,833 |
| Tax expenses recognized in equity |
(320,585,520) |
(346,808,871) |
(140,799,732) |
| Measurement of securities at fair value through other comprehensive income |
(309,559,753) |
(335,837,710) |
(133,417,362) |
| Measurement of cash flow hedge |
(3,361,605) |
(2,628,353) |
(430,444) |
| Measurement of investment hedge |
(1,421,361) |
(1,421,361) |
(1,421,361) |
| Measurement of defined benefit plan |
(6,242,801) |
(6,921,447) |
(5,530,565) |
| Total |
(5,108,056) |
(7,419,514) |
(1,443,123) |
This pertains to deferred tax liabilities recognized
in equity, arising from temporary differences accounted for in equity.
d) Deferred taxes
The balances of “Deferred Tax Assets” and
“Deferred Tax Liabilities” are presented as follows:
| Schedule of balances of tax assets and liabilities |
|
|
|
|
|
|
| Thousand of Reais |
|
|
|
|
2025 |
2024 |
| |
|
|
|
|
|
|
| Deferred Tax Assets |
|
|
|
|
50,854,830 |
48,223,877 |
| Comprising: |
|
|
|
|
|
|
| Temporary differences (1) |
|
|
|
|
45,562,986 |
42,737,528 |
| Tax loss |
|
|
|
|
5,291,844 |
5,486,349 |
| Total deferred tax assets |
|
|
|
|
50,854,830 |
48,223,877 |
| |
|
|
|
|
|
|
| Deferred tax liabilities |
|
|
|
|
4,589,099 |
5,689,440 |
| Comprising: |
|
|
|
|
|
|
| Excess depreciation of leased assets |
|
|
|
414,762 |
394,257 |
| Fair value adjustment of trading securities and derivatives |
|
|
|
|
4,174,337 |
5,295,183 |
| Total deferred tax liabilities |
|
|
|
|
4,589,099 |
5,689,440 |
| (1) |
Temporary differences primarily related to impairment losses on loans and receivables, provisions for judicial and administrative
proceedings, and the effect of the fair value on financial instruments. |
The changes in the balances of “Deferred Tax
Assets” and “Deferred Tax Liabilities” over the last three fiscal years were the following:
| Schedule of changes in the balances of tax assets and liabilities |
|
|
|
|
|
| Thousand of Reais |
Balances at December 31, 2024 |
Adjustment to
Income |
Fair value adjustments (1) |
Other (2) |
Balance on December 31, 2025 |
| |
|
|
|
|
|
| Deferred Tax Assets |
48,223,877 |
3,110,827 |
(573,469) |
93,595 |
50,854,830 |
| Temporary differences |
42,737,528 |
3,305,332 |
(573,469) |
93,595 |
45,562,986 |
| Tax loss |
5,486,349 |
(194,505) |
- |
- |
5,291,844 |
| Deferred Tax Liabilities: |
5,689,440 |
(1,194,298) |
247,771 |
(153,814) |
4,589,099 |
| Temporary differences |
5,689,440 |
(1,194,298) |
247,771 |
(153,814) |
4,589,099 |
| Total |
42,534,437 |
4,305,125 |
(821,240) |
247,409 |
46,265,731 |
| |
|
|
|
|
|
| Thousand of Reais |
Balances at December 31, 2023 |
Adjustment to
Income |
Adjustments to fair value (1) |
Other (2) |
Balance on December 31, 2024 |
| |
|
|
|
|
|
| Deferred Tax Assets |
43,445,704 |
3,124,515 |
2,460,496 |
(806,838) |
48,223,877 |
| Temporary differences |
37,877,300 |
3,206,570 |
2,460,496 |
(806,838) |
42,737,528 |
| Tax loss |
5,561,066 |
(74,717) |
- |
- |
5,486,349 |
| CSLL 18% |
7,338 |
(7,338) |
- |
- |
- |
| Deferred Tax Liabilities: |
3,699,432 |
2,238,539 |
597,555 |
(846,086) |
5,689,440 |
| Temporary differences |
3,699,432 |
2,238,539 |
597,555 |
(846,086) |
5,689,440 |
| Total |
39,746,272 |
885,976 |
1,862,941 |
39,248 |
42,534,437 |
(1) Refers to the tax recognized in equity.
(2) In 2025, it refers mainly to the net of deferred taxes
in the amount of R$247,409 (2024 – R$39,248 and 2023 – R$63,753), which have the same counterparty and realization period.
e) Expected realization of deferred
tax assets
| Schedule of expected realization of deferred tax assets |
|
|
|
|
|
| |
Deferred Tax Assets |
Deferred Tax Liabilities |
| Year |
Temporary differences |
Tax losses |
Total |
Temporary differences |
Total |
| 2026 |
9,572,148 |
36,844 |
9,608,992 |
1,092,810 |
1,092,810 |
| 2027 |
6,937,859 |
1,090,696 |
8,028,555 |
1,095,782 |
1,095,782 |
| 2028 |
6,129,936 |
2,304,325 |
8,434,261 |
870,727 |
870,727 |
| 2029 |
5,162,834 |
1,854,527 |
7,017,361 |
850,912 |
850,912 |
| 2030 |
4,908,139 |
3,730 |
4,911,869 |
151,612 |
151,612 |
| 2031 to 2035 |
12,852,070 |
1,722 |
12,853,792 |
222,694 |
222,694 |
| After 2036 |
- |
- |
- |
304,562 |
304,562 |
| Total |
45,562,986 |
5,291,844 |
50,854,830 |
4,589,099 |
4,589,099 |
|