Glencore, the London-listed commodities trading and mining company, is contesting a £264 million tax bill issued by HM Revenue and Customs (HMRC). The dispute forms part of a broader £1.6 billion investigation into the company’s activities spanning from 2007 to 2023.

HMRC alleges that Glencore shifted certain trading profits from the United Kingdom to its Swiss operations, where the corporate tax rate is lower. The tax authority argues that this arrangement has resulted in unpaid taxes within the UK jurisdiction. Conversely, Glencore maintains that HMRC’s demand is procedurally flawed, contending that the tax authority issued its preliminary notices approximately 18 months beyond the legally permissible timeframe for such claims.

Both Glencore and HMRC have declined to provide comments on the ongoing case. Following news of the dispute, Glencore’s shares fell by 9½ pence, or about 1.7 percent, closing at 551½ pence.

The case highlights the complexities multinational corporations face in navigating differing tax regimes and regulatory requirements across jurisdictions, as well as the contentious nature of profit allocation between associated entities in tax assessments. The outcome may have broader implications for tax enforcement practices relating to profit shifting and transfer pricing strategies used by global firms.