6. Taxes

6.1. Income tax

6.2. Reconciliation of effective tax rate

In 2024 and 2023, the Corporate Income Tax rate (CIT) applied to companies operating in Portugal was 21%. For companies with a positive tax result, there is a surcharge of 1.5% regarding municipal tax, and an additional state tax that varies between 3%, 5% and 9%, for taxable profits higher than €1,500 thousand, €7,500 thousand and €35,000 thousand respectively.

JMH’s effective tax rate is significantly influenced by the fiscal effect of the dividend income received from subsidiaries. This income is not subject to taxation according with the current tax legislation, as it has already been considered for Income Tax purposes in the companies which generated them.

6.3. Deferred tax assets and liabilities

Deferred taxes were updated considering that from 2025 the CIT base rate in Portugal will be reduced to 20%.

JMH did not recognised any amounts in deferred taxes regarding uncertain tax positions.

6.4. Receivable or payable income tax

Income tax reflected on the balance sheet is as follows:

Since 1 January 2014, JMH integrates a group of companies taxed according with the Special Group Taxation Regime (RETGS), as the dominant Company of the group. In addition to JMH, the taxation group is currently composed of the following companies:

• Recheio, SGPS, S.A.
• Recheio – Cash & Carry, S.A.
• Imocash – Imobiliário de Distribuição, S.A.
• Larantigo – Sociedade de Construções, S.A.
• Trade Wings, S.A.
• Recheio Masterchef, Lda.
• Jerónimo Martins – Serviços, S.A.
• Desimo, Lda.
• Jerónimo Martins – Agro-Alimentar, S.A.
• Terra Alegre Lacticínios, S.A.
• Best-Farmer – Actividades Agro-pecuárias, S.A.
• Seaculture – Aquicultura, S.A.
• Ovinos da Tapada – Agropecuária, Lda.
• Outro Chão – Agricultura Biológica, Lda.
• João Gomes Camacho, S.A.
• Jerónimo Martins – Restauração e Serviços, S.A.
• Jerónimo Martins Inovação, S.A.
• Santa Maria Manuela Turismo, S.A.

6.5. Unrecognised deferred taxes on tax losses

JMH did not recognise deferred tax assets related to tax losses in respect of which, with reasonable accuracy, no sufficient future taxable profits are expected to guarantee the recovery of deferred tax assets in the short and/or medium-term. According with the legislation in force in Portugal, there is not a limit period of time for carrying forward tax losses. Total unrecognised deferred tax asset as of 31 December 2024 amounts to €17,395 thousand (2023: €15,815 thousand).

6.6. International Tax Reform – Pillar 2

Under Directive (EU) 2022/2523 of December 14, which introduced the rules of the so-called Pillar 2 in the EU, JMH is considered as “constituent entities” covered by the new rules in the period from 2024, being part of a Group in which the ultimate parent entity is Sociedade Francisco Manuel dos Santos Holding NV (SFMS).

JMH expects that no additional tax will be due in Portugal, with reference to the period of 2024 due to the application of the transitional safe harbours provisions based on financial and tax information of the Country-by-Country Report (“Transitional CbCR Safe Harbours”) for the fiscal year 2023 and based on additional financial information regarding to the fiscal year 2024.

At this date it is not anticipated that these new taxation rules will have a significant impact on the Financial Statements, with no amount recognized in taxes in the income statement, related to Pillar 2, on 31 December 2024.