Glencore takes HMRC to court to void £264m tax bill it says was issued 18 months too late

From the Newshound archive · first published 28 September 2026 · last updated 29 September 2026.

Mining and commodities giant Glencore is challenging a £264 million diverted profits tax assessment in a London court, arguing that HMRC sent its preliminary notices close to 18 months past the statutory deadline. The case is one element of a much larger £1.6 billion dispute over whether Glencore's UK trading arm artificially shifted profits to its lower-tax Swiss parent between 2007 and 2023. Sam Grodzinski KC, acting for Glencore, contends that HMRC's reliance on a four-year extension limit is "entirely inconsistent" with the underlying legislation.

HMRC's standard window for issuing notices is two and a half years, but the authority argues a four-year limit applies because Glencore did not submit a disclosure form for potential cross-border avoidance.