First Read: LatAm Fuel Distribution "Gov’t challenges resellers tax cred..."

Research evidence excerpt

First Read: LatAm Fuel Distribution "Gov’t challenges resellers tax cred..."

Global Research

10 June 2026ab

First Read

LatAm Fuel Distribution Equities

Gov’t challenges resellers tax credits under Americas

LC192/194 Oil Companies, Major

Tasso Vasconcellos

Analyst

tasso.vasconcellos@ubs.com

STJ resumed today judgment on LC 192/194 credits for resellers +55-11-2767 6683

Eixos reported that Brazil’s Superior Court of Justice (STJ) resumed today the Matheus Enfeldt

judgment on whether the government can charge back from resellers PIS/Cofins tax Analyst

credits granted under Complementary Law (LC) 192 and 194/2022. As a recap, the matheus.enfeldt@ubs.com

law allowed distributors/resellers to continue recognizing tax credits even after +55-11-2767 6975

fuel tax cuts, which the government has been challenging the interpretation. In our Joao Barichello

view, the main risk for distributors in our coverage lies in the implications of a Associate Analyst

potential ruling invalidating credits recognition for resellers. Vibra, Ultrapar and joao-pedro.barichello@ubs.com

Raízen have already used part of these credits and still have amounts to be +55-11-2767 6364

recovered on their balance sheets. The companies remain confident with a Victor Modanese

consistent thesis for them, but a potential loss of credits and/or the claim for Associate Analyst

retroactive payments would be materially negative for the sector. Total historically victor.modanese@ubs.com

booked tax credits represent 7/20% of current UGPA/VBBR market cap. +55-11-2767 6008

How much did each distributor recognize in credits?

Vibra: In September 2024, received a favourable ruling from TRF-2 on credit

recognition, updating LC 192 credits to cR$4bn at the time. Including both LC 192