Brazilian Court Rules in Favor of Vale in Foreign-Tax Dispute

By Rogerio Jelmayer

SAO PAULO--Mining giant Vale SA (VALE), the world's top iron-ore producer, won a partial victory in a tax dispute with the Brazilian government over taxes on profits from overseas operations.

Brazil's Superior Court ruled Vale units in Denmark, Belgium, and Luxembourg must pay taxes in those countries but not also in Brazil because those countries have agreements with the Brazilian government that bar double taxation.

Vale and other Brazilian companies have been forced to pay taxes in other countries in which they operate and in Brazil.

Brazil's federal government said it would appeal the decision to the Supreme Court.

However, the Superior Court ruled Vale must pay taxes in Brazil over its activity in Bermuda because Brazil has no agreement on double taxation with the government there.

Vale didn't comment on the court decision nor the disclose the amount of taxes on those international units.

The tax dispute hurt Vale's results in the fourth quarter of 2013, when the company suffered its biggest quarter loss ever. Vale reported a net loss of $6.45 billion for that quarter, more than double the $2.65 billion loss posted in the year-before period.

Vale attributed the losses to an agreement set in November to pay 22.33 billion reais ($9.9 billion) to the Brazilian government to settle a dispute over back taxes it allegedly owed for profits on its overseas operations.

Write to Rogerio Jelmayer at [e-mail]

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