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ADDITIONAL QUESTIONS SUBMITTED BY ABC FOUR CORNERS

GLENCORE RESPONSE 2 NOVEMBER 2017

1. Has Glencore been under audit or risk review in the past by the Australian Tax Office
over its use of Cross Currency Interest Rate Swaps on its related party loans? If yes, when
and how was this resolved (including a figure on any payments made to the ATO)?

Glencore response: Glencore voluntarily participates in a Pre-lodgement compliance review


process with the ATO. As part of this process, the ATO discusses and reviews all significant
tax matters relating to Glencores business in a relevant income year. Any use of cross
currency interest rate swaps on related party loans has been disclosed and discussed with
the ATO. Our use of cross currency interest rate swaps has not been the subject of an audit
and no payments have been required to be made to the ATO.

2. Has Glencore been under audit or risk review by the Australian Tax Office in the past
over its use of high levels of debt? If yes, when and how was this resolved (including a
figure on any payments made to the ATO)?

Glencore response: No. Glencore has been reducing its debt levels within its Australian
operations consistently with Glencore plcs broader debt reduction initiatives. We expect
our Australian operations debt levels to have reduced by about US$4 billion by the end of
2017, driven by asset sales and improved profitability.

The ATO has reviewed the financing arrangements of our Australian business in the past
and no adjustments or payments have been required.

3. Has Glencore been under audit or risk review in the past by the Australian Tax Office
over its trading and/or marketing hub operations in Switzerland? If yes, when and how
was this resolved (including a figure on any payments made to the ATO)?

Glencore response: As noted in our response to the Senate Committee in 2015 we have three
matters on which we continue to engage with the ATO. US$42m has been paid to the ATO
pending resolution of these matters

4. When did Glencore stop using cross currency interest rate swaps for its Australian
operation?

Glencore response: Cross currency interest rate swaps were no longer required once we
aligned our accounting and tax reporting to USD from 2016 onwards.
Where foreign exchange volatility exists in our Australian operations, the use of hedging
arrangements may be considered to manage that risk. We consider the management of
foreign exchange risk to be in line with ordinary commercial business practices of
companies.
It is noted that a single cross currency interest rate swap is on foot to manage foreign
exchange volatility associated with AUD denominated bonds issued by Glencore Australia
Holdings. Both the swap and the bonds are with third parties.

5. Was that in part or in whole due to action by the ATO (not including the private binding
ruling you have referred to)?

Glencore response: No, not in part or in whole.

6. In the 2014-15 tax transparency report, Glencore disclosed that eight entities AZSA
Holdings, Clermont Coal Mines, GHP 104 160 689, Glencore Australia Investment
Holdings, Glencore Investment, Oakbridge, Resource Pacific Holdings, Ulan Coal Mines
made revenues of $18.5 billion, a taxable income of $188 million and tax paid of $54.8
million. Are these the correct figures for Glencores revenue, taxable income and tax paid
for the 2014-15 tax year?

Glencore response: We refer you to the ATTACHED fact sheet which we posted to our
Australian website when the ATO released its report in December 2016.

ENDS

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