Vale gets little relief for $15.5 bln tax debt from court ruling

jueves 11 de abril de 2013 20:05 CEST

* Ruling only impacts Vale for 1996-2001 taxes

* Bulk of foreign unit tax case remains unresolved

* Decision may raise risk for Brazil multinationals

By Jeb Blount

RIO DE JANEIRO, April 11 (Reuters) - A Brazilian Supreme Court ruling on Wednesday will trim global miner Vale SA's 30.5 billion real ($15.5 billion) disputed tax liability by about 5 percent while leaving the bulk of the debt up to future decisions by Brazil courts, company documents show.

The court's complex and incomplete decision on the constitutionality of Brazilian tax rules for foreign subsidiaries only resolved related Brazilian tax assessments on Vale for the 1996-to-2001 period.

That period makes up most of a 1.5 billion real tax bill, plus interest and penalties, that Vale received in 2007 for the profits at foreign units in 1996-2002, according to Vale filings with securities regulators.

The rules being challenged came in effect in 2001 and cannot be applied retroactively, the court said. Vale general counsel Clovis Torres called the decision a "great victory" late Wednesday. He said it would make a significant dent in the company's tax liability.

The other 29 billion real of Vale liabilities under the 2001 regulations remain unresolved by the courts after more than a decade of litigation. And while Vale has the biggest tax debt under the 2001 rules, other companies also face assessments.   Continuación...