Shares of Ambev (ABEV3) fell 3.5% on allegations of tax leaks and rebates at beverage giants; analysts see exaggerated movement

A new noise hits the shares of Ambev (ABEV3) in this Wednesday’s session (1). If, after the scandal of accounts in Americanas (AMER3), ABEV3 assets had a negative performance on the stock market (with a drop of 8%) because they share the trio of shareholders Carlos Alberto Sicupira, Jorge Paulo Lemann and Marcel Telles This time, a more direct allegation over an alleged default by the beverage maker has impacted assets on the stock exchange, although analysts have many reservations on the matter and see the reaction as exaggerated.

Shortly after the market opened, around 10:30 (Brasilia time), Veja’s Radar Econômico column published a study carried out by AC Consultoria and commissioned by the Associação Brasileira da Indústria da Cerveja (CervBrasil), which represents Ambev’s smaller producers. The association pointed to an estimated gap of R $ 30 billion in alleged tax maneuvers carried out by beverage companies.

The publication reports that the study would accuse Ambev of inflating the price of the components necessary for the production of the soft drink and which are subject to exemption and generation of tax credits in the Manaus Free Zone, which would lead to the irregular accumulation of more credits tax than would have been fair.

As a result, the shares started to fall around 4% (on a bad day for Ibovespa) and reached a low of R$12.85 for the day, or a drop of 5.93%. At the close of the session, ABEV3 shares closed down 3.51% to R$13.18.

In a statement, Ambev defended himself by stating that “Cervbrasil’s accusations have no foundation. We calculate all of our tax credits strictly according to the law. Our financial statements comply with all regulatory and accounting standards, including the transparency of tax litigation. Ambev is among the top 5 taxpayers in Brazil”.

Later, economist André Paiva, of AC Consultores, told the O Antagonista portal that the BRL 30 billion dispute concerns the entire cold drinks industry in the Manaus free trade zone, of which Ambev is a part. Paiva couldn’t say the specific value of the brewery, but said the issue itself deserves further investigation. THE Money info was given access to the study and Ambev’s name was not mentioned.


Even before the clarification, the news had already been viewed with reservations by many market analysts. Banks like Credit Suisse and BTG Pactual saw the move as exaggerated.

BTG points out that CervBrasil is the association that represents Grupo Petrópolis (GP) and other smaller Brazilian breweries, having historically been vocal and vehemently opposed to tax credits generated by companies such as Ambev and Coca-Cola in the production of soft drink concentrates in the Zona Franca de Manaus (ZFM).

In essence, companies operating in the ZFM are exempt from IPI, but those who buy concentrate from them can still recognize tax credits based on the nominal IPI rate. He also recalls that the 30 billion reais mentioned in the article, in fact, refer to estimates of federal revenue relating to tax credits accumulated in litigation between tax authorities and beverage companies. Therefore, he points out, the part possibly relating to Ambev is “undoubtedly much smaller”.

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The bank recalls that this story goes back a long way since, since the days of the Temer government, the government has tried to reduce IPI credit on concentrates to reduce this bias. The credit consists of a refund made by the State to the companies in the credit sector for the payment of the DPI. The lead is down from a 20% basis in
August 2018 at the current 8%, which means that a good part is already lost. Indeed, this is an important reason for the margin pressure that Coca-Cola Group (KO) bottlers operating in Brazil in recent years, assesses the bank.

In the case of Ambev, the impact should be even smaller given the size of Non-Alcohol Beverages (NAB) for the whole business (7% of the projected Ebitda, or earnings before interest, taxes, amortization expected for 2022.

“So, any discussion regarding possible changes in the functioning of the ZFM has to be very diluted,” BTG points out, noting that there is not much news on this topic.


Based on Q3 2022 data, Ambev has BRL 5.6 billion in “possible” losses related to tax credits associated with the Manaus Free Trade Zone (just under 3% of market value).

But it seems fair to say that, if these credits cease to exist, companies will likely pass some of these costs on to prices, BTG analysts estimate. They cite other possible risks they see as greater, such as a potentially broader tax reform that could address tax incentives associated with interest on principal payments (JCPs), in addition to the challenging macro scenario. “So we think this particular noise is greatly exaggerated, but we remain neutral on Ambev’s actions,” they say.

An analyst interviewed by Money info he also mentions that Ambev reports up to BRL 5.6 billion as a “possible” risk, but other amounts have already been removed due to a Federal Supreme Court (STF) ruling.

Furthermore, the specialist sees the BRL 30 billion figure suspiciously reported, but which, even if correct, would not break Ambev, “which is much higher” [que a Americanas]. But, it reinforces, the expectation that there was an event like this to happen after the “Americanas case” ended up influencing the action.

Goldman Sachs, which has a sell recommendation for the stake, highlights some other numbers, but reinforcing that Ambev has a strong balance sheet. Ambev, he points out, has 86.9 billion reais in possible unprovisioned tax risks (including personal income tax and social security contributions, ICMS and IPI, PIS and Cofins and other disputes), while it records a cumulative balance of 986 million reais in provisions for disputes and litigation in general.

It should be noted that, a day earlier, Citi highlighted that Ambev’s shares are under pressure due to the controversy involving Americanas and 3G Capital, but the company should not be affected by the retailer’s judicial recovery process.

The bank’s analysts also point out that the beverage maker’s current shareholder agreement runs through 2034, making it very unlikely that the trio of billionaires will sell off assets to try to shore up Americanas’ operations.

Operationally, Ambev is also experiencing a relatively favorable operational and competitive moment, occupying a leadership position in its market and with growth that reduces risks. Citi has a buy recommendation for Ambev, with a target price of R$18.50.

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