A Closer Look at the Tax Reform's Implications
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Key Conclusions On July 13, Deputy Celso Sabino (Brazil’s tax reform rapporteur) published a revised version of the income tax reform bill originally sent to Congress on June 25. We believe that this new version has a greater chance of being approved and will likely be voted on in the Lower House A Closer Look at after the August recess. We believe that the new proposal favors growth over yield. In this report, we analyze the implications of the revised proposal for companies and investors. The tax reform is mostly positive for companies, given the positive impact of the reduced the Tax Reform’s income tax rate, which would be only partially offset by the end of the interest-on-equity (IoE) tax benefit. The Health Care, Financials and Retail sectors are poised to be the main winners. For Food & Beverage, Telecom and Banks the impact would be net-negative, mostly due to the end of the Implications IoE tax benefit. For retail investors the tax reform will be mostly negative, because they will be obligated to pay a 20% dividend tax if the reform is approved; currently, retail investors do not pay taxes July 26, 2021 on dividends. Dividends are already incorporated into the performance of institutional investors, who pay capital gains taxes on them. Strategy Team 1 Marcelo Sa, CNPI Matheus Marques +55-11-3073-3011 +55-11-3073-3255 1 [email protected] matheus. [email protected] Our Views on the Rapporteur’s Tax Reform Proposal Key takeaways: i) greater reduction in the income tax rate; ii) dividend Dividend taxation versus corporate taxes: The dividend taxation and the taxation provision retained; iii) interest-on-equity tax benefit still eliminated. reduction in corporate taxes would better align Brazil with global standards. Greater income tax reduction: the rapporteur proposed a 10% reduction of the income tax rate 55 in 2022 (from 2.5% in the original bill) and a 12.5% cut from 2023 onward (from 5% in the original 50 IRE bill). 45 KOR Dividends: The new proposal retains the originally proposed 20% dividend tax and the DEN 40 elimination of the IoE tax benefit. UK CAD 35 ISR CLP BEL FRA Removal of the dividend tax at the subsidiary level. Dividend taxes would not have to be SWE US 30 FIN NOK collected from subsidiaries if the dividends were paid to the controlling shareholder. This is an SLO AUS GER POR important improvement from the original bill, reducing potential tax inefficiencies. Under the 25 TUR ITA NTH AUD ICE SPA original bill, the controlling shareholder would get a credit for the dividend taxes collected at the SWI LUX BRL Original Proposal 20 POL BRL New JPY subsidiary level but could only use it to offset taxes on dividends. If the company chooses to (%) profit 15 HUN LIT Proposal MXN invest in a new project, for example, it would not be able to use the credit, increasing its overall CZK NZD taxation. In the case of minority stakes, however, dividend taxes would be collected at the 10 COP SLK subsidiary level, making this type of partnership less attractive. In our view, if this proposal is 5 GRE LAT BRL today approved, companies will be incentivized to sell their minority stakes. 0 EST Other notable revisions: i) removal of the provision that would establish new terms for the use of on distributed ratetax income Corporate 8 10 12 14 16 18 20 22 24 26 28 30 32 34 36 goodwill amortization; and ii) removal of the provision that would subject companies with lease- Tax rate before distribution - corporate tax (%) based revenues exceeding 50% of total revenue to the “real profit” tax regime, which would have a negative impact on malls and other commercial properties. Breakdown of the fiscal impact: The federal government estimates a greater Fiscal impact: The federal government expects a net negative impact of BRL 30 negative impact on tax collection for states and municipalities than for the billion in 2023, while Itaú’s Macro team projects it to be mostly neutral. federal government. 24 24 25 25 9 15 15 14 1 1 1 -5 -6 -1 -1 -15 -16 -10 -13 -15 -12 -18 -17 -14 -16 -22 -24 -28 -30 -30 -28 -30 Fed Govt estimates Itau estimates Fed Govt estimates Itau estimates Fed Govt estimates Itau estimates Fed Govt estimates Itau estimates 2022 2023 2022 2023 Total Individuals Corporates Subsidies Funds taxation Total Impact Fed Gov State and Municipalities Source: Itaú BBA, Itaú Macro, OCDE 2 Analyzing the Impact on Companies Impact on Fair Value – Most Benefited Companies Fair value and EPS sensitivity analysis. These calculations are very 28.4% complex, as there are several factors that must be considered: 21.7% 21.4% The negative impact of the end of the interest-on-equity benefit may offset or partially 19.2% 19.2% 18.9% 18.5% 18.5% offset the gains from the income tax reduction. We estimate a net negative impact for 18.2% 18.2% Ambev, Vivo and Banco do Brasil. Some utilities (discos and water utilities) will not benefit from the reduction in the income taxes, as this gain will be passed through consumer tariffs. See Slide 22. Companies with operations outside Brazil, such as JBS, will likely register a neutral or slightly positive impact from the reduction in the income tax rate. Companies with complex corporate structures – i.e., that have some of their gains taxed MBLY3 MATD3 TFCO4 CXSE3 SBFG3 AMER3 WIZS3 PNVL3 ESPA3 GMAT3 outside Brazil even though their production is in Brazil – will benefit less from the income tax reduction. Impact on Fair Value – Least Benefited Companies Companies that are subject to the “presumed profit” tax regime or other special tax regimes will also benefit less, as they currently pay low income taxes. Companies in the Homebuilders and Education sectors will gain very little from the income tax reduction. ABEV3 CSMG3 MDIA3 SBSP3 BBAS3 VIVT3 BPAC11 MYPK3 INTB3 BIDI11 We see a small income tax rate reduction for companies with the SUDAM/SUDENE benefit: the effective tax rate will fall to 12.13% from 15.25%. -2.0% -2.4% -2.2% -2.1% Banking names will benefit less from the income tax reduction, given their loss of tax -3.9% credits. Moreover, banks will suffer from the end of the IoE benefit. -4.4% -5.0% Companies that take advantage of tax incentives, such as Intelbras, will not benefit much -6.7% from the reduction in the income tax rate. -7.1% -10.5% Source: Itaú BBA 3 Fair Value and 2023 EPS Impact Average Impact on Fair Value - Sector 16.0% 13.0% 12.3% 12.0% 10.7% 10.4% 8.9% 8.1% 7.7% 6.1% 5.5% 5.2% 2.1% 0.8% 0.4% -1.4% -5.7% Tech Retail Banks Protein Utilities Oil & Gas Oil & Financials Education Health CareHealth Pulp & PaperPulp Agribusiness Homebuilders Steel & Mining Steel Properties Goods Food& Beverage Telecom & Media Malls & Commercial Malls Average Impact on EPS (2023) - Sector Transportation &Capital 15.0% 14.4% 12.2% 11.4% 11.4% 9.3% 8.4% 8.0% 7.5% 6.2% 6.0% 4.9% 3.2% 1.3% 0.8% -1.4% -4.3% Tech Retail Banks Protein Utilities Oil & Gas Oil & Financials Education Health CareHealth Pulp & PaperPulp Agribusiness Homebuilders Steel & Mining Steel Properties Capital Goods Capital Food& Beverage Transportation & Telecom & Media Malls & Commercial Malls Source: Itaú BBA 4 Analyzing the Impact for Retail Investors Final Tax Reform Impact for Retail Investors, Including Dividend Taxation (% of Fair Value) – Companies For retail investors the tax reform will be mostly negative, because they will be obligated to pay a 20% dividend tax if the reform is approved; currently, retail BBAS3 BRSR6 ABEV3 ABCB4 CSMG3 SANB11 CAML3 BPAN4 BEEF3 MDIA3 investors do not pay taxes on dividends. Dividends are already incorporated into the performance of institutional investors, who pay a capital gains taxes on them. We ran a sensitivity analysis adjusting for the negative impact of the dividend tax. The Retail, Pulp & Paper and Oil & Gas sectors are poised to be the main winners, as they have high growth and do not pay much in dividends. The Food & Beverage, Banking and Homebuilders sectors are likely to benefit the -18.5% least. Banking and Food & Beverage (Ambev) companies typically pay high dividends -19.6% -19.1% -19.0% -18.6% -21.8% -21.6% and interest on equity. Homebuilders pay low income taxes and are expected to pay -22.9% good dividends in the medium term. -24.8% -30.8% Final Tax Reform Impact for Retail Investors, Including Dividend Taxation (% of Fair Value) – Sectors 6.4% 5.4% 3.5% 3.1% 2.1% 1.8% 0.6% 0.3% -2.0% -4.7% -7.0% -7.3% -7.4% -8.3% -11.4% -18.0% -20.2% Tech Retail Banks Protein Utilities Oil & Gas Oil & Financials Education Health CareHealth Pulp & PaperPulp Agribusiness Homebuilders Steel & Mining Steel Properties Goods Food& Beverage Telecom & Media Malls & Commercial Malls Transportation &Capital Source: Itaú BBA 5 Agribusiness Sector Overview The Agribusiness sector should be positively affected by the tax reform, as the 12.2% companies we cover do not make significant IoE payouts. 9.4% 10.4% The positive impact on SLC is likely to be the lowest in our coverage universe, as the company pays the most own-capital IoE. 0.3% Rumo has not paid IoE historically and should benefit the most, while the impact on Hidrovias is likely to be lower due to the SUDAM tax benefit.