Our Approach to Tax in the UK
Our Business
Vale Base Metals Limited (the “Company”), a UK-incorporated company, and its subsidiaries (collectively referred to as "the Group") are engaged in the exploration, extraction, milling, smelting, refining, distribution, and marketing of copper and nickel products. This includes copper concentrate, copper cathode, high-purity class I, and class II nickel products. The Group also produces cobalt, precious metals, and platinum group metals (PGMs) as by-products of copper and nickel mining and processing. The Group primarily sells its products in North America, Europe, and Asia.
Vale Base Metals Limited is the holding company of the Group, with headquarters in the United Kingdom. The Group's primary mining and processing facilities are in Canada and Brazil, with stand-alone refineries in the United Kingdom and Japan.
The Company is a 90% subsidiary of Vale International SA ("VISA") in Switzerland and is controlled by Vale. Vale is a public company headquartered in Rio de Janeiro, Brazil, with its securities traded on the São Paulo exchange B3 S.A. (BOVESPA: VALE3), the New York Stock Exchange (NYSE: VALE) and the unregulated electronic market established by the Madrid Stock Exchange for the trading of Latin American securities (LATIBEX: XVALO).
For more information on our global business, please click here.
We conduct our business activities guided by a set of values that reflect high ethical and moral standards, aimed at assuring credibility and preserving the company’s image in the markets in which it regularly operates, in the short and long term and this extends to our approach to tax.
As a business, our main commitments are:
- To promote complete transparency in terms of governance, policy, procedures, practices and the Vale’s performance to our global stakeholders;
- To pursue opportunities that contribute to global targets’ achievements related to our business, by seeking partnerships, solutions and technology for challenges to sustainable development;
- To work harmoniously with our stakeholders to contribute to the construction of a positive legacy for future generations, balancing the social, environmental, and economic aspects of our business, and
- To monitor and anticipate trends in global themes of sustainability by developing, adopting, sharing, and promoting insights of best practices, to continuously improve our performance.
Our tax approach outlined below applies to our UK entities.
Our approach to tax risk management and governance
Our approach to tax is set by the Global tax compliance team which supports the Group’s business activities and commitments. The Global tax compliance team implemented a global compliance program with the involvement of local experts in each country in which the Group operates, to assist and support local Finance teams to ensure that each of the affiliates comply with local laws and requirements for tax purposes.
The Company is the indirect parent company of Vale Europe Limited, a UK-incorporated company that performs toll refining services in the UK. The tax function for the Group is led by the Head of Accounting, Tax & Financial Reporting, and as such, those with responsibility for the Group’s tax matters report to that position, including the team responsible for tax matters at Vale Europe Limited. The Head of Accounting, Tax & Financial Reporting reports to the Group’s Chief Financial Officer (CFO) and, in turn, to the Board of Directors of the Company (the “VBML Board’), and ultimately to the Board of Directors of the Vale S.A., where necessary.
The VBML Board is accountable for Group’s affairs. Tax matters are also regularly discussed with other business functions, whether at corporate and/or refinery management meetings, to ensure that the tax implications of significant business developments are appropriately considered.
We aim to ensure that our tax returns are prepared accurately and submitted in a timely manner. We ensure that duties are segregated while preparing our returns. For example, separate individuals review the tax returns before they are submitted.
We aim for certainty in our tax positions. In some cases, when the law is not clear, we will have effective frameworks in place to identify, monitor, control and manage our tax risks, in compliance with the tax policies of the Group, considering a position that is possible to be accepted upon examination by the relevant Tax Court. We aim at a fair, stable and competitive tax system with reduced litigation while delivering appropriate tax revenues to governments to support economic growth and development for the local communities, job creation and viable long-term tax contributions.
Our attitude to tax planning
Our approach to tax is conservative and aligned with the commercial activities of our business, the legislation in force and broader group policies. We benefit from government incentives in a manner as intended by the government; these include capital allowances. The Base Metals Tax team provides support and additional expertise on uncertain UK tax matters where necessary. Significant tax decisions in the UK are discussed with the Head of Accounting, Tax & Financial Reporting to ensure that our approach to tax is consistent with the broader group policies. In addition to this, we will seek third-party advice from external expert advisors as necessary.
Our approach to engaging with tax authorities
We maintain an open, transparent, and collaborative relationship with HMRC in the UK. We are in regular contact with our Customer Compliance Manager at HMRC and proactively discuss significant tax matters and business developments.
This tax strategy has been prepared in accordance with the requirements of paragraph 19 (2) contained within Schedule 19 of the Finance Act 2016.