structure was undertaken without a valid
business purpose. The 2001 reorganization was comparable with
restructurings done by many companies in Brazil. The original
dispute was resolved in the courts in the Group’s favor. However,
in 2013 a new assessment was raised in respect of a similar matter.
Additionally, during the course of 2014, and between 2017 and 2020,
other notices of infringement were issued based on the same grounds
argued in the previous assessments. The total amount of the tax
assessments in respect of this matter as at December 31, 2020
was €2,040 million (2019: €2,235 million).
The Group believes that the
likelihood that the Brazilian tax authorities will ultimately
prevail is low, however there can be no guarantee of success in
court. In each case we believe our position is strong, so they have
not been provided for and are considered to be contingent
liabilities. Due to the fiscal environment in Brazil, the
possibility of further tax assessments related to the same matters
cannot be ruled out. We expect that two of our largest tax
litigation cases, which represent around €863 million of
contingent liabilities, will move from the Administrative to the
Judicial Courts during 2021, although the exact timing is
uncertain. When this happens, we will be required to make a
judicial deposit or provide a guarantee in respect of the disputed
tax, interest and penalties. The judicial process in Brazil is
likely to take a number of years to conclude.
UCC was incorporated under the
laws of the State of Delaware on October 7, 1982 for the sole
purpose of issuing and selling debt securities and making the net
proceeds of such issues available to companies in the Unilever
Group. All the common stock of UCC is owned by UNUS. Its registered
office is at 1209 Orange Street, Wilmington, Delaware 19801. Its
principal place of business is at 700 Sylvan Avenue, Englewood
Cliffs, New Jersey 07632, United States of America (telephone
number +1 201 894 7042).
The Directors of UCC
Unilever United States,
UNUS was incorporated under the
laws of the State of Delaware on August 31, 1977. UNUS has its
registered office at 1209 Orange Street, Wilmington, Delaware
19801. The principal place of business of UNUS is at 700 Sylvan
Avenue, Englewood Cliffs, New Jersey 07632, United States of
America (telephone number +1 201 894 2829).
UNUS’ principal operating
subsidiary, Conopco, Inc., a New York corporation, has three
principal product categories — home care products, personal care
products and food and refreshment products.
Home care products include
household cleaners, dishwashing, laundry products. Major brands
include Seventh Generation, Love & Care, Love Home &
Planet, The Laundress and Schmidt’s.
Personal care products include
antiperspirants and deodorants, hair and skin care products, as
well as soap. Major brands include AXE, Dove, Suave, Lever 2000,
Caress, Degree, Pond’s, Vaseline, TIGI (Bed Head, Cat Walk and
S-Factor), TRESemmé, Nexxus, Dermalogica, Living Proof, Schmidt’s,
Love Beauty & Planet, St. Ives, Simple, Noxzema, Dollar Shave
Club and Q-tips cotton swabs.
Food and refreshment products
include Lipton teas, Ben & Jerry’s, Breyers, Good-Humor,
Klondike, Magnum, Popsicle and Talenti ice creams and frozen
novelties; Lipton soups, recipe products and side dishes; Knorr
bouillons, gravies, sauces, recipe classics and side dishes; and
Hellmann’s (and Best Foods) mayonnaise and dressings.
The Directors of UNUS