ArcelorMittal Faces Multiple Tax Reassessment Notices in France

Overview

• On Wednesday, ArcelorMittal confirmed it received reassessment notices covering the 2012–2020 and 2021–2022 periods that target commissions paid to a Luxembourg affiliate (AMS), an Industrial Franchise Agreement and the interest rate on an intercompany loan.
• The company says it formally contested the proposed rectifications in writing in February 2024 and February 2025 and filed appeals that were ongoing at the end of 2025 but later described as no longer active for some cases.
• A labour court in Valenciennes ordered AM Centre de services to hand tax-control documents for 2021–2025 to a CGT Métallurgie branch, a step that could enable workers to seek higher profit-participation payments if fiscal corrections reduce reported profits.
• ArcelorMittal’s public filings show global tax exposures at end-2025 of $242 million for income-tax uncertainties and $177 million in other tax provisions, while the specific amounts for the French reassessments have not been disclosed.
• Tax authorities regularly scrutinise transfer pricing because it moves profit across borders, the DGFiP declined to comment, and the next developments to watch are appeal rulings and the group’s formal disclosures in its 20-F and other filings.