On November 21, 2005, Law No. 11.196 was enacted allowing the offsetting of INSS debts against federal tax credits. This procedure was regulated by Interministerial Ordinance No. 23 dated February 2, 2006. In addition, article 2 of Law 11.457/07 establishes responsibility to the Brazilian Federal Revenue Service concerning the employees’ social security contributions levied on their contribution salaries, according to item c, sole paragraph, Article 11 of Law 8.212/91 and
Article 104 of Law 11.196/05. The Corporation currently has a favorable court decision that determines that the Federal
Revenue Service of Brazil should analyze the requests for Reimbursement filed by the Corporation and also establishes the recognition of the possibility to offset credits related to PIS and COFINS taxes with social security contributions, upon use of tax credits to pay the dues.The Corporation believes it holds sufficient credits to settle its debits and therefore, based
on the opinion of its legal counsel, is carrying out the offset of social security debts with PIS/COFINS tax credits. An Interlocutory Appeal was filed by the National Treasury against said court decision, which was judged and the decision maintained with regard to the requirement of analysis by the Federal Revenue Service of Brazil of the requests for Reimbursement filed by the Corporation. However, the decision was altered regarding the right to suspend the
enforceability of the dues. As a result, the Corporation requested the court to recognize the possibility of offsetting
the PIS and COFINS credits with social security contributions using the tax credits to pay the debts, to be undertaken by the Federal Revenue Service of Brazil. To formalize said credits, the Corporation filed Requests for Reimbursement with the
Federal Revenue Service of Brazil. These requests indicate the existence of sufficient credits to settle the Corporation’s debts, at the occasion of occurrence of the facts and events, using the tax credits to pay such debts. However, given the start of the period to include dues settled with PIS and COFINS credits, which has been challenged by Brazil’s Federal Revenue Service, in order to improve its positioning and relationship with them, the Corporation chose to include the dues settled
until December 2013 in the World Cup REFIS. Consequently, the credits settled were once again included in the balance sheet (see Note 9.2 and 16). This does not mean that the Corporation has withdrawn or changed its opinion, as
mentioned above, and therefore for dues after December 31, 2013, use of tax credits to pay dues will continue to be requested.In the year ended December 31, 2014, the Corporation does sponsor post-employment benefit plans with actuarial liability characteristics.
Taxes payable