13.1 Income tax and social contribution

The income tax and social contribution taxes are based on tax rates for 25% for income tax and 9% for social contribution in Brazil. For other regions in which the Company operates, the expected nominal rates are as follows:

Income taxes reported in the income statement are broken down as follows:

The reconciliation between the weighted nominal tax rate and the effective tax rate is summarized below:

The main events that impacted the effective tax rate for the period were:

13.2 Deferred income tax and social contribution

The amounts of deferred income tax and social contribution for each type of temporary difference are as shown below:

Most 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 follows the applicable fiscal and accounting rules.

The Management’s critical estimates regarding main contingent liabilities related to uncertainty on income tax treatments are disclosed in note 27.2 – Contingencies.

13.2.1 Realization of deferred taxes

As at December 31, 2025, the deferred tax assets and liabilities are expected to be utilized/settled, as follows:

13.2.2 Net change in deferred taxes

The net change in deferred income tax and social contribution is as follows:

13.2.3 Deferred tax asset related to tax losses

Beyond the tax credits related to tax losses effectively recognized as part of the amounts disclosed above, there are other tax credits related to tax losses that were not recorded in the balance sheets due to their low expectations of realization, based on Management’s assessment. As at December 31, 2025, the accumulated balance of these credits represented R$991.5 in taxable value (R$867.0 in 2024 and R$669.0 in 2023), equivalent to a taxable basis of R$3,788.7 in December 31, 2025 (R$3,310.1 in 2024 and R$2,521.0 in 2023).

Additionally, tax credits related to tax losses recorded in the Brazilian ECF (Tax Accounting Bookkeeping), for the purpose of calculating Taxation on a worldwide basis, ceased to be recognized, resulting in a principal amount of R$5,289.5 as of December 31, 2025.

Accounting policies

Income tax and social contribution for the year comprises current tax and deferred tax. Income tax and social contribution are recognized in the income statement, unless they relate to items recognized directly in comprehensive income or in other equity accounts. In these cases, the tax effects are also recognized directly in comprehensive income or in equity accounts (except for interest on shareholders’ equity. See note 22 - Changes in equity.

Deferred income taxes are calculated on temporary differences between their calculation bases and the Company's accounting data. The deferred tax assets are recognized only to the extent that is probable that future taxable profits will be available. The deferred income tax assets are reduced to the extent that it is no longer probable that future taxable profits will occur. The existence of future taxable income is based on a technical study approved by the Company's management.

IAS 12 - “Income Taxes” prescribes that no deferred tax liability on goodwill recognition, and no deferred tax asset/liability is recorded: (1) at the initial recognition of an asset or liability in a transaction other than a business combination that at the time of the transaction affects neither accounting nor taxable profit or loss and (2) on differences related to investments in subsidiaries to the extent that they are not reversed in the foreseeable future. The amount of deferred tax provided is based on the expectation of the realization or settlement of the temporary difference, using currently or substantially enacted tax rates.

Deferred tax assets and liabilities are offset if there is a legally enforceable right to offset current tax liabilities and assets, and where these relate to income taxes levied by the same tax authority on the same taxable entity, or to different taxable entities which intend either to settle their current tax liabilities and assets on a net basis, or to realize the assets and settle the liabilities simultaneously.

The company is subject to income tax in numerous jurisdictions and judgment is required to determine the Company’s worldwide provision for income tax. Some of the Company's subsidiaries are involved in tax audits, usually in relation to previous years. These audits are ongoing in various jurisdictions as at the balance sheet reporting date and, by their nature, can take a considerable time to be completed.

Uncertainties regarding the treatment of income taxes

The Company applies the provisions of IFRIC 23 - Uncertainty on the Treatment of Income Taxes in relation to the treatments that affected the calculation of income taxes (uncertain tax treatments), as disclosed in note 27.2 - Provisions, Contingent Liabilities and Contingent Assets - Uncertainties about treatment of IRPJ and CSLL.

Rules of the “Pillar Two”

In December 2021, the Organization for Economic Cooperation and Development (“OECD”), as part of the Inclusive Framework on Base Erosion and Profit Shifting (“BEPS”) project, published the Global Anti-Base Erosion Model Rules (GloBE), which are part of the project known as “Pillar Two.” The aim is to establish a common approach to international corporate taxation, ensuring that multinational economic groups within the scope of these rules pay income taxes at a minimum effective rate of 15% in each country where they operate. These rules must be locally approved in each country that adheres to the proposal through applicable legislation, with some already having enacted internal laws for implementation or being in the process of discussion and approval.

For the Group, the Pillar Two have been in effect since 2024 in certain jurisdictions, with no material impact during that period. In Brazil, Law No. 15,079/24, resulting from Provisional Measure No. 1,262/24 and regulated by Normative Instruction RFB No. 2,228/24, became effective on January 1, 2025, and implemented the GloBE rules at the domestic level through the introduction of the Additional CSLL, aimed at ensuring a domestic minimum effective taxation of 15%.

For the fiscal year 2025, the Company assessed the effects of the legislation for Brazil and other jurisdictions of the Group that have implemented the regime and concluded that there was no material impact during the period.