Glencore (LSE:GLEN) is challenging a £264 million ($498.81 million) UK tax demand, arguing that notices covering two financial years were issued after the applicable deadline.
The Financial Times reports that the proceedings concern diverted profits tax assessments of £113 million for 2019 and £151 million for 2020.
Glencore argues that the UK’s HM Revenue and Customs (HMRC) issued preliminary notices about 18 months after the standard two-and-a-half-year assessment period had expired.
HMRC maintains that a four-year deadline applies because Glencore did not formally notify the agency of a potential diverted profits tax liability. The company says HMRC already held the relevant information and had previously indicated that a separate notification was unnecessary.
Diverted profits tax applies to arrangements that HMRC considers have shifted profits outside the UK or otherwise reduced the amount of UK corporate tax payable.
The dispute forms part of a wider examination of Glencore’s tax arrangements. HMRC alleges the company’s UK trading business shared risks with its Swiss parent in a manner that moved taxable profits from the UK to Switzerland between 2007 and 2023. Glencore disputes the assessments.
The company is seeking to have the £264 million demand set aside and the amount repaid. The court has not announced a decision.
According to Glencore’s 2026 half-year report, the company has appealed broader UK tax assessments covering 2007–2023. A Switzerland–UK mutual agreement process did not resolve the dispute, and Glencore says it intends to pursue independent arbitration.
Glencore is a diversified resources company producing and marketing commodities including copper, coal, zinc, nickel, and cobalt.
Write to France Pinzon at Mining.com.au
Main image: Glencore
