Material Fact – Tax Transaction

MATERIAL FACT

Rio de Janeiro, January 29, 2024. ATMA Participações S.A. – In Judicial Reorganization (“Company” or “ATMA” or “ATMP3”), under the terms of Resolution 44/2021 of the Brazilian Securities and Exchange Commission – CVM, informs its shareholders and the general market that, on this date the Company and its subsidiaries entered into an Individual Transaction Agreement (“Agreement”) with the National Treasury Attorney’s Office (“PGFN”), under the terms of Law 13,988/2020 and PGFN Ordinance No. 6,757/2022.

The Agreement aims to restructure the Company’s tax liabilities, allowing it to resume its tax regularity and fulfill its tax obligations. The restructuring involved a readjustment of the amount owed by the Company and a re-profiling of the payment schedule.

The total amount of the debts renegotiated in the Agreement is approximately R$558.8 million, and this amount will be deducted by the conversion of judicial deposits, use of tax losses and effective reductions in the value of tax credits, with (i) the balance remaining, after deductions, paid within a period of 60 months for social security debts and 120 months for other debts managed by the Brazilian Federal Revenue Service and (ii) the installments added the SELIC Rate variation. Payments will be made in a staggered manner with the aim of adapting the balance of federal tax liabilities to the real payment capacity of the Company and its subsidiaries.

The Company estimates an impact of around R$391 million on the respective tax liabilities, from the current value of R$558.8 million to R$167.9 million.

The effects of the Agreement will be reflected in the Company’s next fiscal statements, to be made available to the market within the deadlines established by art. 22, III, and art. 27, § 2, of Resolution No. 80/2022 of the Brazilian Securities and Exchange Commission – CVM.

Norair Ferreira do Carmo
Chief Financial and Investor Relations Officer