The Superior Court of Justice in Brazil has arrived at a decision in relation to the mining company Vale. The Court has ruled that profits of Controlled Foreign Companies (CFCs) of Vale in Belgium, Luxembourg, and Denmark would not give rise to a Brazilian tax liability owing to the provisions of double tax treaties concluded by Brazil with those countries. The Court agreed with the taxpayer that the CFC rules should only apply where there is no double taxation treaty with a particular country. The decision is however likely to be appealed by the Brazilian government.
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