Bunge Global SABG
Bunge Global SA Income Taxes Disclosure
INCOME TAXES
Bunge operates globally and is subject to the tax laws and regulations of numerous tax jurisdictions and authorities as well as tax agreements and treaties among these jurisdictions. Bunge's income tax provision is impacted by, among other factors, changes in tax laws, regulations, agreements and treaties, currency exchange rates and Bunge's profitability in each tax jurisdiction.
Bunge prospectively adopted ASU 2023-09 in the fourth quarter of 2025. As a result, Bunge expanded disclosures for the components of Income tax expense, effective tax rate reconciliation, and information on income taxes paid for the year ended December 31, 2025.
The components of Income from continuing operations before income tax are as follows:
| Year Ended December 31, | |||||||||||||||||
| (US$ in millions) | 2025 | 2024 | 2023 | ||||||||||||||
| United States | $ | 326 | $ | 442 | $ | 1,180 | |||||||||||
| Non-United States | 808 | 1,082 | 1,871 | ||||||||||||||
| Total | $ | 1,134 | $ | 1,524 | $ | 3,051 | |||||||||||
The components of the Income tax expense from continuing operations are as follows:
| Year Ended December 31, | |||||||||||||||||
| (US$ in millions) | 2025 | 2024 | 2023 | ||||||||||||||
| Current: | |||||||||||||||||
Federal (1) | $ | 37 | |||||||||||||||
State and Local (1) | 2 | ||||||||||||||||
| United States | 39 | $ | 107 | $ | 218 | ||||||||||||
| Non-United States | 311 | 239 | 497 | ||||||||||||||
| 350 | 346 | 715 | |||||||||||||||
| Deferred: | |||||||||||||||||
Federal (1) | 34 | ||||||||||||||||
State and Local (1) | (17) | ||||||||||||||||
| United States | 17 | 18 | 46 | ||||||||||||||
| Non-United States | (79) | (28) | (47) | ||||||||||||||
| (62) | (10) | (1) | |||||||||||||||
| Total | $ | 288 | $ | 336 | $ | 714 | |||||||||||
(1)In the fourth quarter of 2025, Bunge prospectively adopted ASU 2023-09. In accordance with the standard, Bunge has provided incremental disaggregation of Income tax expense from continuing operations in the United States for the year ended December 31, 2025.
Reconciliation of Income tax expense from continuing operations if computed at the U.S. federal income tax rate to Bunge’s reported Income tax expense for the year ended December 31, 2025 is as follows:
| Year Ended December 31, | |||||||||||
| (US$ in millions) | 2025 | ||||||||||
| Income tax at U.S. federal tax rate | $ | 238 | 21% | ||||||||
U.S. state taxes, net of federal income tax effect (1) | (15) | (1.3) | |||||||||
| Non-U.S. tax effects | |||||||||||
| Argentina: | |||||||||||
| Inflation tax benefit | (40) | (3.5) | |||||||||
| Non-deductible remeasurement | 80 | 7.1 | |||||||||
| Earnings taxed at a different statutory rate | 21 | 1.8 | |||||||||
| Incremental tax on future distributions | 14 | 1.2 | |||||||||
| Other | (6) | (0.5) | |||||||||
| Brazil: | |||||||||||
| Earnings taxed at a different statutory rate | 36 | 3.2 | |||||||||
| Tax credits | (13) | (1.1) | |||||||||
| Other | 14 | 1.2 | |||||||||
| Canada | 19 | 1.7 | |||||||||
| Italy: | |||||||||||
| Changes in valuation allowance | (30) | (2.7) | |||||||||
| Other | 2 | 0.2 | |||||||||
| The Netherlands: | |||||||||||
| Changes in valuation allowance | (40) | (3.5) | |||||||||
| Other | 6 | 0.5 | |||||||||
| Romania | 13 | 1.1 | |||||||||
| Switzerland: | |||||||||||
| Changes in valuation allowance | (45) | (4.0) | |||||||||
| Other | 3 | 0.3 | |||||||||
| Ukraine: | |||||||||||
| Changes in valuation allowance | 23 | 2.0 | |||||||||
| Other | 2 | 0.2 | |||||||||
| Other non-U.S. jurisdictions | 18 | 1.6 | |||||||||
Enactment of new tax laws (2) | — | — | |||||||||
Effect of cross-border tax laws (2) | — | — | |||||||||
Tax credits (2) | — | — | |||||||||
Changes in valuation allowance (2) | — | — | |||||||||
Non-taxable or non-deductible items (2) | — | — | |||||||||
| Changes in unrecognized tax benefits | (12) | (1.1) | |||||||||
Other adjustments (2) | — | — | |||||||||
| Income tax expense | $ | 288 | 25.4% | ||||||||
(1)State taxes in Missouri made up the majority (greater than 50%) of the tax effect in this category.
(2)The impact of individual reconciling items using a dash are not material to the consolidated financial statements considering the nature and relative significance of the reconciling item.
The U.S. is a significant market for Bunge globally, and Bunge maintains its corporate operational headquarters in the U.S. along with significant business operations. Additionally, Bunge has used the U.S. federal statutory rate to reconcile its
effective tax rate for at least 25 years, despite not being domiciled in the U.S. during that period. In order to maintain consistency and relevance for users of the financial statements, the reconciliation between the provision for income taxes and income tax at the statutory rate is presented on the basis of the U.S. federal statutory rate instead of the Swiss national rate.
As previously disclosed for the years ended December 31, 2024 and 2023, prior to the adoption of ASU 2023-09, the reconciliation of income tax expense if computed at the U.S. federal income tax rate to Bunge's reported income tax expense is as follows:
| Year Ended December 31, | ||||||||||||||
| (US$ in millions) | 2024 | 2023 | ||||||||||||
| Income before income tax | $ | 1,524 | $ | 3,051 | ||||||||||
| Income tax rate | 21% | 21% | ||||||||||||
| Income tax expense at the U.S. Federal tax rate | 320 | 641 | ||||||||||||
| Adjustments to derive effective tax rate: | ||||||||||||||
| Foreign earnings taxed at different statutory rates | (10) | 142 | ||||||||||||
| Valuation allowances | 21 | (30) | ||||||||||||
Fiscal incentives (1) | (13) | (76) | ||||||||||||
| Foreign exchange on monetary items | 21 | (5) | ||||||||||||
| Tax rate changes | — | 18 | ||||||||||||
| Non-deductible expenses | 62 | 40 | ||||||||||||
| Uncertain tax positions | 15 | 20 | ||||||||||||
| Inflation adjustments | (84) | (32) | ||||||||||||
| Incremental tax on future distributions | 5 | 25 | ||||||||||||
| State taxes | 18 | 22 | ||||||||||||
| Gain on BP Bunge Bioenergia disposal | (44) | — | ||||||||||||
Swiss tax credits, net (2) | — | (90) | ||||||||||||
| Other | 25 | 39 | ||||||||||||
| Income tax expense | $ | 336 | $ | 714 | ||||||||||
(1)Fiscal incentives predominantly relate to investment incentives in Brazil that are exempt from Brazilian income tax.
(2)During 2023, Bunge was granted tax credits in Switzerland that expire through 2032, and recorded a net benefit for the amount that Bunge believes is more likely than not to be realized prior to expiration.
The primary components of the deferred tax assets and liabilities and the related valuation allowances are as follows:
| December 31, | |||||||||||
| (US$ in millions) | 2025 | 2024 | |||||||||
| Deferred income tax assets: | |||||||||||
| Net operating loss carryforwards | $ | 746 | $ | 548 | |||||||
| Operating lease obligations | 277 | 124 | |||||||||
| Employee benefits | 73 | 58 | |||||||||
| Tax credit carryforwards | 471 | 410 | |||||||||
| Interest deduction carryforwards | 298 | 119 | |||||||||
| Accrued expenses and other | 219 | 140 | |||||||||
| Total deferred tax assets | 2,084 | 1,399 | |||||||||
| Less valuation allowances | (890) | (595) | |||||||||
| Deferred tax assets, net of valuation allowance | 1,194 | 804 | |||||||||
| Deferred income tax liabilities: | |||||||||||
| Property, plant and equipment | 874 | 317 | |||||||||
| Inventories | 3 | 1 | |||||||||
| Operating lease assets | 282 | 123 | |||||||||
| Undistributed earnings of affiliates | 19 | — | |||||||||
| Investments | 51 | 18 | |||||||||
| Intangibles | 63 | 79 | |||||||||
| Total deferred tax liabilities | 1,292 | 538 | |||||||||
| Net deferred tax (liabilities) assets | $ | (98) | $ | 266 | |||||||
As of December 31, 2025, Bunge has determined it has certain unremitted earnings that are considered to be indefinitely reinvested and no provision for income taxes has been made. If these earnings were distributed in the form of dividends or otherwise, Bunge would be subject to income taxes in the form of withholding taxes to the recipient. The determination of the amount of withholding taxes is not practicable.
At December 31, 2025, Bunge's pre-tax loss carryforwards totaled $2.5 billion, of which $2.2 billion have no expiration, including loss carryforwards of $1.2 billion in Brazil. While loss carryforwards in Brazil can be carried forward indefinitely, annual utilization is limited to 30% of taxable income calculated on an entity-by-entity basis as Brazil tax law does not allow consolidated tax filings. At December 31, 2024, Bunge's pre-tax loss carryforwards totaled $1.9 billion, of which $1.7 billion have no expiration, including loss carryforwards of $1.2 billion in Brazil. The increase in pre-tax loss carryforwards from 2024 to 2025 is primarily attributable to the Viterra Acquisition. The remaining tax loss carryforwards expire at various periods through the year 2045.
At December 31, 2025, Bunge’s tax credit carryforwards totaled $471 million, of which $169 million expire in 2029, $249 million expire in 2032, while the remainder is split between a portion expiring within a ten year period and a portion that has no expiration. At December 31, 2024, Bunge's tax credit carryforwards totaled $410 million.
Income Tax Valuation Allowances—Bunge records valuation allowances when current evidence does not suggest that some portion or all of its deferred tax assets will be realized. The ultimate realization of deferred tax assets depends primarily on Bunge's ability to generate sufficient timely future income of the appropriate character in the appropriate taxing jurisdiction.
As of December 31, 2025 and 2024, Bunge has recorded valuation allowances of $890 million and $595 million, respectively. The net increase of $295 million is primarily attributable to valuation allowances recorded in purchase accounting as part of the Viterra Acquisition.
Unrecognized Tax Benefits—ASC 740, Income Taxes ("ASC 740") requires applying a "more likely than not" threshold to the recognition and de-recognition of tax benefits. Accordingly, Bunge recognizes the amount of tax benefit that has a greater than 50 percent likelihood of being realized upon settlement. At December 31, 2025 and 2024, respectively, Bunge had
recorded unrecognized tax benefits of $77 million and $75 million in Other non-current liabilities in the consolidated balance sheets, inclusive of accrued interest and penalties of $10 million and $11 million at December 31, 2025 and 2024, respectively. During 2025, 2024 and 2023, respectively, Bunge recognized $(1) million, $2 million, and less than $1 million of interest and penalty charges in Income tax expense in the consolidated statements of income. A reconciliation of the beginning and ending amounts of unrecognized tax benefits follows:
| (US$ in millions) | 2025 | 2024 | 2023 | ||||||||||||||
| Balance at January 1, | $ | 127 | $ | 121 | $ | 298 | |||||||||||
| Additions based on tax positions related to the current year | 6 | 9 | 13 | ||||||||||||||
| Additions based on acquisitions | 18 | — | — | ||||||||||||||
| Additions based on tax positions related to prior years | — | 10 | 12 | ||||||||||||||
Reductions for tax positions of prior years (1) | (2) | (2) | (206) | ||||||||||||||
Settlements with tax authorities (2) | (49) | (2) | — | ||||||||||||||
| Expiration of statute of limitations | (15) | (4) | (5) | ||||||||||||||
| Foreign currency translation | 9 | (5) | 9 | ||||||||||||||
| Balance at December 31, | $ | 94 | $ | 127 | $ | 121 | |||||||||||
(1)The year ended December 31, 2023 included reductions of the tax position in Spain resulting from the conclusion of an appeals process. This decrease had no impact on the consolidated statement of income as the position was not previously recognized under ASC 740.
(2)The year ended December 31, 2025 included settlements with tax authorities in Spain resulting from the conclusion of an appeals process. This decrease had no impact on the consolidated statement of income as the position was not previously recognized under ASC 740.
Bunge, through its subsidiaries, files income tax returns in the United States (federal and various states) and non-United States regions. The table below reflects the tax years for which Bunge is subject to income tax examinations by tax authorities in significant tax regions:
| Open Tax Years | |||||
| North America | 2016 - 2025 | ||||
| South America | 2018 - 2025 | ||||
| Europe, Middle East, and Africa | 2017 - 2025 | ||||
| Asia-Pacific | 2015 - 2025 | ||||
As of December 31, 2025, Bunge's Brazilian subsidiaries have received income tax and penalty assessments through 2018 of approximately R$4.3 billion (approximately $790 million) plus applicable interest on the outstanding amount. Bunge has recorded unrecognized tax benefits related to these assessments of R$7 million (approximately $1 million) as of December 31, 2025.
Management, in consultation with external legal advisors, believes that it is more likely than not that Bunge will prevail on the proposed assessments (with the exception of unrecognized tax benefits discussed above) in Brazil and is vigorously defending its position against these assessments.
A summary of cash income tax payments, net of refunds received, for the year ended December 31, 2025 is as follows:
| Year Ended December 31, | |||||
| (US$ in millions) | 2025 | ||||
| Federal | $ | 50 | |||
| State | 11 | ||||
| Non-United States | |||||
| Argentina | 22 | ||||
| Australia | (35) | ||||
| Brazil | (32) | ||||
| Canada | 16 | ||||
| Germany | 24 | ||||
| The Netherlands | 15 | ||||
| Romania | 11 | ||||
| Singapore | 13 | ||||
| Switzerland | 14 | ||||
| Spain | 23 | ||||
| Other | 54 | ||||
| Total | $ | 186 | |||
Bunge made cash income tax payments, net of refunds received, of $186 million, $520 million and $655 million during the years ended December 31, 2025, 2024 and 2023, respectively.
On July 4, 2025, H.R.1, commonly known as the "One Big Beautiful Bill Act", was signed into U.S. law. Bunge evaluated the provisions of the law and its potential impact on the consolidated financial statements. The One Big Beautiful Bill Act did not have a material impact on the consolidated effective tax rate in 2025 and the Company expects it to be immaterial in 2026 as well. This assessment considers various factors, including the nature of its operations and the specific tax law changes introduced by the law. The law allows for the immediate expensing of qualified capital expenditures (100% bonus depreciation), and Bunge anticipates that this provision will result in additional cash tax benefits for the Company, primarily by accelerating tax deductions for eligible investments in property, plant, and equipment. While this immediate expensing is expected to reduce the Company's current cash tax obligations, it is not anticipated to materially alter its effective tax rate over the long term, consistent with current accounting standards for deferred taxes.
Historical Timeline
| Fiscal Year | Filed | |
|---|---|---|
| 2025 | Feb 19, 2026 | Showing above |
| 2024 | Feb 20, 2025 | |
| 2023 | Feb 22, 2024 | |
About Income Taxes Disclosures
The income tax disclosure reveals how much a company actually pays in taxes versus what the statutory rate would predict. Analysts focus on the effective tax rate (ETR) reconciliation, which breaks down every item driving the gap between the 21% federal rate and the company's reported ETR — including R&D credits, foreign rate differentials, and state taxes. Deferred tax assets (DTAs) and their valuation allowances signal management's confidence in future profitability: a rising allowance suggests the company doubts it can use accumulated tax benefits. Uncertain tax benefit (UTB) reserves quantify exposure to IRS challenges on aggressive positions.
Key signals to watch: sudden ETR drops without clear operational reasons, large increases in valuation allowances, growing UTB balances, and significant unremitted foreign earnings. Post-TCJA, pay attention to GILTI and BEAT provisions that affect multinational tax structures. Compare the cash taxes paid (from the cash flow statement) against the income tax provision to gauge earnings quality.