Vale case could change the way Brazil taxes foreign profits
22 March 2012
A tax dispute involving the world’s second largest mining company, Vale, and the Brazilian Federal Revenue Service (RFB), could overhaul Brazil’s approach to the taxation of overseas profits.
RFB is pursuing Vale for more than R$27 billion ($14.84
billion) in taxes, including interest and penalties, for
assessments on profits of its foreign subsidiaries and
affiliates carried out between 1996 and 2008.
Last week, the Superior Court of Justice (STJ) suspended a
lower court ruling and granted Vale a temporary restraining
order against all payment demands made by RFB and suspended the
requirement to post bond with the court to continue contesting
It is uncertain when the final STJ judgement will be made,
as the ruling, in connection with other pending cases, could
significantly alter Brazil's rules for taxing foreign
"The Vale case has received a lot of attention because of
the high amounts and...
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