Petróleo Brasileiro S.A.- Petrobras, in continuity to the notice to the market disclosed on April 8, 2024, informs that the Board of Directors approved, with 10 (ten) votes in favor, today, the Company’s adherence to the PGFN-RFB Transaction Public Notice 6/2024 (tax disputes of significant and widespread legal controversy), which covers debts whose tax collections are subject to administrative or judicial litigation related to discussions on “IRRF, CIDE, PIS and COFINS taxes on remittances abroad, resulting from the bipartition of legal transactions agreed in platform chartering contracts and other services, under the terms of Law 9,481, of August 13, 1997”.
The total value of the transaction, considering the 65% discount granted in the public notice, is R$19.80 billion, of which R$6.65 billion will be paid with the judicial deposits already made in the lawsuits and R$1.29 billion will be paid with tax loss credits from subsidiaries. The remaining R$11.85 billion will be paid as follows, with any subsequent increases due to adjustments and the updating of charges up to the date of actual payment:
– A down payment of R$3.57 billion, paid on June 30, 2024;
– Remaining balance paid in six successive monthly installments of approximately R$1.38 billion each. The first installment will be paid on July 31, 2024, and the others on the last business day of the following months, adjusted by the SELIC rate.
The impact on net income in 2Q24, after taxes, will be of approximately R$11.87 billion.
This adhesion will allow the conclusion of administrative and judicial discussions relating to CIDE, PIS and COFINS from 2008 to 2013, in the total amount of R$44.79 billion. The contractual modeling used by the Company was corroborated by Laws 13.043/2014 and 13.586/2017 and, as a result, since 2014 the infraction notices in this matter have ceased. The full amount is detailed in Note 19.3 – Litigations not provisioned in the financial statements (DFP) for the 2023 fiscal year.
Several partners in the E&P consortiums are responsible for approximately 13% of this transaction litigation and Petrobras is negotiating with other consortium members the reimbursement conditions of the amounts relating to their respective shares.
Adhesion to the Program results in financial benefits to the Company, since maintaining these discussions would imply in a financial effort to offer and maintain legal guarantees, in addition to other procedural costs and expenses.
Finally, adherence to the Program was analyzed by the Statutory Audit Committee and the Company’s Minority Committee, which did not identify any obstacles to its implementation.
Brazil Energy Insight 
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