PBF Energy Inc.
PBF Energy Inc. Income Taxes Disclosure
INCOME TAXES
(a) State and local taxes in California and Louisiana comprise the majority of this category.
PBF Energy is required to file federal and applicable state corporate income tax returns and recognizes income taxes on its pre-tax income, which to-date has consisted primarily of its share of PBF LLC’s pre-tax income (see “Note 13 - Stockholders’ and Members’ Equity Structure”). PBF LLC is organized as a limited liability company and PBFX is a partnership, both of which are treated as “flow-through” entities for federal income tax purposes and therefore are not subject to income taxes apart from the income tax attributable to the two subsidiaries acquired in connection with the acquisition of Chalmette Refining and PBF Holding’s wholly-owned Canadian subsidiary, PBF Energy Limited, that are treated as C-Corporations for income tax purposes, with the tax provision calculated based on the effective tax rate for the periods presented.
The income tax provision in the PBF Energy Consolidated Statements of Operations consists of the following:
| Year Ended December 31, | |||||||||||||||||
| (in millions) | 2025 | 2024 | 2023 | ||||||||||||||
| Current expense (benefit): | |||||||||||||||||
| Federal | $ | 1.7 | $ | (10.6) | $ | 140.9 | |||||||||||
| Foreign | — | — | (0.3) | ||||||||||||||
| State | 2.1 | 21.4 | 46.2 | ||||||||||||||
| Total current | 3.8 | 10.8 | 186.8 | ||||||||||||||
| Deferred (benefit) expense: | |||||||||||||||||
| Federal | (48.5) | (156.6) | 387.7 | ||||||||||||||
| Foreign | 3.2 | (4.8) | 3.1 | ||||||||||||||
| State | (32.6) | (77.8) | 146.2 | ||||||||||||||
| Total deferred | (77.9) | (239.2) | 537.0 | ||||||||||||||
| Total provision for income taxes | $ | (74.1) | $ | (228.4) | $ | 723.8 | |||||||||||
Income Tax Payments (Refunds)
Disclosed below is a summary of income taxes paid (refunds received) by jurisdiction for the year ended December 31, 2025:
| Year Ended December 31, 2025 | |||||
| Federal | $ | (71.1) | |||
| State and local | (6.4) | ||||
| Foreign | — | ||||
| Total income tax refund | $ | (77.5) | |||
In the year ended December 31, 2025, the Company received a federal income tax refund of approximately $72.0 million. There were no other individual jurisdictions with cash taxes paid or refunds received that equaled or exceeded 5% of total income taxes paid.
Reconciliation of Statutory Federal Income Tax Rate to the Effective Income Tax Rate
The difference between PBF Energy’s effective income tax rate and the United States statutory rate for the year ended December 31, 2025 is reconciled below:
| Year Ended December 31, 2025 | |||||||||||
| $ | % | ||||||||||
| Provision at Federal statutory rate | $ | (48.8) | 21.0 | % | |||||||
| Increase (decrease) attributable to flow-through of certain tax adjustments: | |||||||||||
State and local income taxes (net of federal income tax) (a) | (22.5) | 9.7 | % | ||||||||
| Nondeductible/nontaxable items | |||||||||||
| Executive compensation | 8.0 | (3.4) | % | ||||||||
| Non-taxable incentive income | (7.0) | 3.0 | % | ||||||||
| Equity compensation | (2.5) | 1.1 | % | ||||||||
| Other | 0.5 | (0.2) | % | ||||||||
| Rate differential from foreign jurisdictions | (0.7) | 0.3 | % | ||||||||
| Other | (1.1) | 0.4 | % | ||||||||
| Effective tax rate | $ | (74.1) | 31.9 | % | |||||||
The difference between PBF Energy’s effective income tax rate and the United States statutory rate for the years ended December 31, 2024 and December 31, 2023 are reconciled below:
| Year Ended December 31, | |||||||||||
| 2024 | 2023 | ||||||||||
| Provision at Federal statutory rate | 21.0 | % | 21.0 | % | |||||||
| Increase (decrease) attributable to flow-through of certain tax adjustments: | |||||||||||
| State income taxes (net of federal income tax) | 5.0 | % | 5.0 | % | |||||||
| Nondeductible/nontaxable items | 3.3 | % | (0.5) | % | |||||||
| Rate differential from foreign jurisdictions | (0.2) | % | — | % | |||||||
| Provision to return adjustment | 0.2 | % | (0.1) | % | |||||||
| Other | 0.7 | % | (0.1) | % | |||||||
| Effective tax rate | 30.0 | % | 25.3 | % | |||||||
PBF Energy’s effective income tax rate for the years ended December 31, 2025, 2024 and 2023, including the impact of income (loss) attributable to noncontrolling interests of $(2.0) million, $(6.4) million and $21.5 million, respectively, was 31.6%, 29.7% and 25.1%, respectively.
For the years ended December 31, 2025 and December 31, 2024, PBF Energy’s effective tax rate differed from the United States statutory rate, inclusive of state income taxes, as a result of equity-based compensation activity and permanent book/tax differences related to the use of blender’s tax credits. For the year ended December 31, 2023, PBF Energy’s effective tax rate did not materially differ from the United States statutory rate, inclusive of state income taxes.
For financial reporting purposes, income (loss) before income taxes attributable to PBF Energy Inc. stockholders includes the following components:
| Year Ended December 31, | |||||||||||||||||
| (in millions) | 2025 | 2024 | 2023 | ||||||||||||||
| United States income (loss) | $ | (244.3) | $ | (739.8) | $ | 2,852.4 | |||||||||||
| Foreign income (loss) | 11.7 | (22.4) | 11.9 | ||||||||||||||
| Total income (loss) before income taxes attributable to PBF Energy Inc. stockholders | $ | (232.6) | $ | (762.2) | $ | 2,864.3 | |||||||||||
A summary of the components of PBF Energy’s deferred tax assets and deferred tax liabilities consists of the following:
| (in millions) | December 31, 2025 | December 31, 2024 | |||||||||
| Deferred tax assets | |||||||||||
| Purchase interest step-up | $ | 141.8 | $ | 165.0 | |||||||
| Inventory | 26.0 | — | |||||||||
| Pension, employee benefits and compensation | 51.5 | 53.3 | |||||||||
| Net operating loss carry forwards | 532.4 | 297.5 | |||||||||
| Environmental liabilities | 38.6 | 39.0 | |||||||||
| Lease liabilities | 293.6 | 317.4 | |||||||||
| Other | 50.4 | 50.7 | |||||||||
| Total deferred tax assets | 1,134.3 | 922.9 | |||||||||
| Deferred tax liabilities | |||||||||||
| Property, plant and equipment | 1,323.9 | 1,122.0 | |||||||||
| Inventory | — | 60.3 | |||||||||
| Right of use assets | 292.2 | 314.5 | |||||||||
| Equity method investment in SBR | 259.6 | 249.6 | |||||||||
| Other | 22.2 | 12.5 | |||||||||
| Total deferred tax liabilities | 1,897.9 | 1,758.9 | |||||||||
| Net deferred tax liability | $ | (763.6) | $ | (836.0) | |||||||
As of December 31, 2025, PBF Energy had $2,009.3 million of gross federal and $111.5 million of net state income tax operating loss carry forwards. The portion of the federal net operating loss carry forward that was generated in years prior to 2019 was utilized in 2022. The federal net operating loss carry forward was generated in 2024 and 2025, and it has an indefinite carryforward period but is limited to 80% of taxable income in each tax year. The state net operating loss carry forwards expire at various dates from 2028 through 2054 with certain jurisdictions having indefinite net operating loss carry forward periods.
Income tax years that remain subject to examination by material jurisdictions, where an examination has not already concluded are all years including and subsequent to:
| United States | |||||
| Federal | 2021 | ||||
| New Jersey | 2021 | ||||
| Michigan | 2021 | ||||
| Delaware | 2022 | ||||
| Indiana | 2022 | ||||
| Pennsylvania | 2022 | ||||
| New York | 2022 | ||||
| Louisiana | 2022 | ||||
| California | 2021 | ||||
The Company does not have any unrecognized tax benefits.
Valuation Allowance
The Company assesses the available positive and negative evidence to estimate whether sufficient future taxable income will be generated to permit use of existing deferred tax assets. Negative evidence evaluated as part of this assessment includes cumulative losses incurred over a three-year period. Such objective evidence could limit PBF Energy’s ability to consider other subjective evidence, such as PBF Energy’s projections for future taxable income as market conditions, commodity prices and demand for refined products normalize.
On the basis of this evaluation, a valuation allowance is recorded to recognize only the portion of deferred tax assets that are more likely than not to be realized. The amount of the deferred tax assets considered realizable, however, could be adjusted if estimates of future taxable income during the carryover period are reduced or increased or if objective negative evidence in the form of cumulative losses is no longer present and additional weight is given to subjective evidence such as PBF Energy’s projections for future taxable income.
One Big Beautiful Bill Act
On July 4, 2025, the One Big Beautiful Bill Act was signed into law in the United States. The legislation includes certain provisions related to the full expensing of qualified United States research and experimental costs and other depreciable property. The legislation also includes changes to the determination of the amount of United States interest expense that is deductible for United States. tax purposes. The legislation did not have a material impact on the Company’s income tax expense for the year ended December 31, 2025, and did not materially change its effective income tax rate for 2025.
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.