INCOME TAXES

12 Months Ended

Dec. 31, 2025

Income Taxes [Abstract]

INCOME TAXES

NOTE 10: INCOME TAXES

The current tax payable (recoverable) is based on taxable

profit (loss) for the year. Taxable profit differs from profit as

reported in the consolidated statements of operations because

it excludes items of income or expense that are taxable or

deductible in other years or are never taxable or deductible.

The Company’s current income tax expense (benefit) is

calculated using tax rates that have been enacted or

substantively enacted as of the date of the consolidated

statements of financial position.

Tax is charged or credited to the consolidated statements of

operations, except when it relates to items charged or credited

to other comprehensive income or directly to equity, in which

case the tax is recognized in other comprehensive income or in

equity.

Deferred tax is recognized on differences between the carrying

amounts of assets and liabilities, in the consolidated financial

statements and the corresponding tax basis used in the

computation of taxable profit, and is accounted for using the

statements of financial position liability method. Deferred tax

liabilities are generally recognized for all taxable temporary

differences, and deferred tax assets are generally recognized

for all deductible temporary differences and net operating loss

carry forwards to the extent that it is probable that taxable

profits will be available against which those deductible

temporary differences can be utilized. Such assets and

liabilities are not recognized if the taxable temporary difference

arises from the initial recognition of non-deductible goodwill or

if the differences arise from the initial recognition (other than in

a business combination) of other assets and liabilities in a

transaction that affects neither the taxable profit nor the profit

reported in the consolidated statements of operations.

Deferred tax liabilities are recognized for taxable temporary

differences associated with investments in subsidiaries,

associates and joint ventures, except if the Company is able to

control the reversal of the temporary difference and it is

probable that the temporary difference will not reverse in the

foreseeable future. Deferred tax assets arising from deductible

temporary differences associated with such investments are

only recognized to the extent that it is probable that there will

be sufficient taxable profits against which the benefits of the

temporary differences can be utilized and are expected to

reverse in the foreseeable future.

Deferred tax assets and liabilities are measured at the tax rates

that are expected to apply in the period in which the liability is

settled or the asset realized, based on tax rates (and tax laws)

that have been enacted or substantively enacted at the

consolidated statements of financial position date. The

measurement of deferred tax assets and liabilities reflects the

tax consequences that would result from the manner in which

the Company expects, at the reporting date, to recover or settle

the carrying amount of its assets and liabilities.

The carrying amount of deferred tax assets is reviewed at each

consolidated statements of financial position date and reduced

to the extent that it is no longer probable that sufficient taxable

profits will be available to enable all or part of the asset to be

recovered. The Company reviews the deferred tax assets in

the different jurisdictions in which it operates to assess the

possibility of realizing such assets based on projected taxable

profit, the expected timing of the reversals of existing

temporary differences, the carry forward period of temporary

differences and tax losses carried forward and the

implementation of planning strategies. Due to the numerous

variables associated with these judgments and assumptions,

both the precision and reliability of the resulting estimates of

the deferred tax assets are subject to substantial uncertainties.

In case a history of recent losses is present, the Company

considers whether convincing other evidence exists, such as

the character of (historical) losses and planning opportunities,

to support the deferred tax assets recognition.

Deferred tax assets and liabilities are offset when there is a

legally enforceable right to set off current tax assets against

current tax liabilities, when they relate to income taxes levied

by the same taxation authority and when the Company intends

to settle its current tax assets and liabilities on a net basis.

Uncertain (income) tax positions are periodically assessed by

the Company based on management’s best judgment given

any changes in the facts, circumstances and information

available and applicable tax laws. When it is probable that the

position taken in the tax return will not be accepted by the tax

authorities, the Group establishes provisions based on the

most likely amount of the liability (recovery) or weighted

average of various possible outcomes to reflect the effect of

the uncertainty in determining the related taxable profit (tax

loss), tax bases, unused tax losses, unused tax credits or tax

rates, to the extent that a reliable estimate can be made.

The Company has adopted International Tax Reform – Pillar

Two Model Rules (Amendments to IAS 12 upon their release

on May 23, 2023). The Amendments provide a temporary

mandatory exception from deferred tax accounting for the top-

up tax, which is effective immediately, and require disclosures

about the Pillar Two exposure from December 31, 2023. The

Company has applied a temporary mandatory relief from

deferred tax accounting for the impacts of the top-up tax and

accounts for it as a current tax when incurred.

Pillar Two legislation has been enacted or substantively

enacted in the jurisdiction of ArcelorMittal S.A., the ultimate

parent of the Group, and in certain other jurisdictions where the

Company operates. The legislation is effective for the

Company’s financial year beginning January 1, 2024. Based

on the applicable criteria, the Company is subject to Pillar Two

minimum tax.

10.1 Income tax expense

The components of income tax expense (benefit) are

summarized as follows:


	Year ended December 31,
	2025	2024	2023
Total current tax expense 1	602	1,025	1,008
Total deferred tax expense (benefit)	(243)	510	(770)
Total income tax expense	359	1,535	238

The following table reconciles the expected tax expense at the

statutory rates applicable in the countries where the Company

operates to the total income tax expense as calculated:


	Year ended December 31,
	2025	2024	2023
Net income (including non- controlling interests)	3,243	1,380	1,022
Income tax expense	359	1,535	238
Income before tax	3,602	2,915	1,260
Tax expense at the statutory rates applicable to income in the countries 2	677	582	454
Permanent items	(487)	(31)	(101)
Rate changes	(29)	370	—
Net change in measurement of deferred tax assets	(68)	182	(423)
Tax effects of foreign currency translation	16	(21)	(20)
Tax credits	(12)	(16)	(26)
Other taxes	199	219	324
Others	63	250	30
Income tax expense	359	1,535	238

1.For the year ended December 31, 2025, current income tax expense

includes 8 of top-up tax in relation to Pillar Two taxation.

2.Tax expense at the statutory rates is based on income before tax excluding

income from investments in associates, joint ventures and other investments.

ArcelorMittal’s consolidated income tax expense is affected by

the income tax laws and regulations in effect in the various

countries in which it operates and the pre-tax results of its

subsidiaries in each of these countries, which can change from

year to year. ArcelorMittal operates in jurisdictions, mainly in

Eastern Europe and Asia, which have a structurally lower

corporate income tax rate than the statutory tax rate as

enacted in Luxembourg (23.87%), as well as in jurisdictions,

mainly in Brazil and Mexico, which have a structurally higher

corporate income tax rate.


Permanent items	Year ended December 31,
	2025	2024	2023
Acquisition gain of Calvert	(444)	—	—
Taxable reversals of (tax deductible) write-downs on shares and receivables	—	—	(647)
Non-deductible loss on disposal of Kazakhstan operations	—	—	573
Juros sobre o Capital Próprio	(1)	(4)	(117)
Other permanent items	(42)	(27)	90
Total permanent items	(487)	(31)	(101)

Acquisition gain of Calvert: The gain recognized in connection

with the acquisition of the 50% stake in AMNS Calvert is non-

taxable.

Taxable reversals of (tax deductible) write-downs on shares

and receivables: in the framework of the Company's

impairment test for goodwill and property, plant and equipment,

the recoverability of the carrying amounts of investments in

shares and intragroup receivables is also reviewed annually,

resulting in tax deductible write-downs, or taxable reversals of

previously recorded write-downs, of the values of loans and

shares of consolidated subsidiaries in Luxembourg.

Juros sobre o Capital Próprio: Corporate taxpayers in Brazil,

which distribute a dividend can benefit from a tax deduction

corresponding to an amount of interest calculated as a yield on

capital. The deduction is determined as the lower of the

interest as calculated by application of the Brazilian long-term

interest rate on the opening balance of capital and reserves,

and 50% of the income for the year or accumulated profits from

the previous year. For accounting purposes, this distribution of

interest on capital is considered as a dividend distribution,

while for Brazilian tax purposes it is considered as tax

deductible interest.

Non-deductible loss on disposal of Kazakhstan operations: the

Company recorded 0.9 billion impairment charges and

1.5 billion foreign exchange translation losses in connection

with the divestment of its operations in Kazakhstan in 2023.

Both items were non-deductible for tax purposes, see note 2.3.

Rate changes

The 29 tax benefit resulting from rate changes in 2025 is due to

the decrease from 30.3% to 25% of the statutory tax rate as

enacted in Germany and applied to deferred taxes. The 370

tax expense resulting from rate changes in 2024 was due to

the decrease from 24.94% to 23.87% of the statutory tax rate

as enacted in Luxembourg and applied to deferred taxes.

Net change in measurement of deferred tax assets

The 2025 net change in measurement of deferred tax assets of

68 mainly consists of (i) 620 recognition of deferred tax assets

in Luxembourg mainly due to the utilization of unrecognized tax

losses carried forward, partly offset by (ii) 552 net

derecognition of deferred tax assets related to negative results

for the current and prior years, primarily in Mexico, and other

tax jurisdictions.

The 2024 net change in measurement of deferred tax assets of

182 mainly consisted of (i) 563 net unrecognition of deferred

tax assets related to negative results for the year in other tax

jurisdictions partly offset by (ii) 381 recognition of deferred tax

assets in Luxembourg mainly due to the utilization of

unrecognized tax losses carried forward.

The 2023 net change in measurement of deferred tax assets of

423 mainly consisted of (i) 314 recognition of deferred tax

assets in Luxembourg including 366 recognition of tax losses

carried forward based on revised taxable income forecast and

(ii) 109 net recognition of deferred tax assets in other tax

jurisdictions, including 292 recognition related to higher future

profits expectations.

Tax effects of foreign currency translation

Tax effects of foreign currency translation of 16, (21) and (20)

at December 31, 2025, 2024 and 2023, respectively, refer

mainly to deferred tax assets and liabilities of certain entities

with a different functional currency than the currency applied

for tax filing purposes.

Tax credits

Tax credits are mainly attributable to the Company’s operating

subsidiaries in Brazil. They relate to credits claimed on foreign

investments, credits for research and development and other

credits.

Other taxes

Other taxes mainly include withholding taxes on dividends,

services, royalties and interests as well as mining duties in

Canada and Mexico, state tax, Corporate Alternative Minimum

Tax ("CAMT"), Base Erosion and Anti-Abuse Tax ("BEAT") in

the U.S., and Cotisation sur la Valeur Ajoutée des Entreprises

("CVAE'') in France.


Others	Year ended December 31,
	2025	2024	2023
Tax contingencies/settlements	97	263	43
Prior period taxes	(28)	(10)	(4)
Others	(6)	(3)	(9)
Total	63	250	30

Tax contingencies/settlements of 97, 263, and 43 at

December 31, 2025, 2024 and 2023, respectively, consist of

uncertain tax positions (see note 10.3) including 202 recorded

in 2024 for expected resolution of the tax disputes in the North

America segment.

10.2 Income tax recorded directly in equity and/or other

comprehensive income


	Year ended December 31,
	2025	2024	2023
Recognized in other comprehensive income on:
Deferred tax expense (benefit)
Gain (loss) on derivative financial instruments	(47)	(107)	(126)
Recognized actuarial gain (loss)	47	17	(18)
Foreign currency translation adjustments	52	4	110
	52	(86)	(34)
Recognized directly in equity on:
Deferred tax expense (benefit)
Loss related to repurchase of MCNs	—	—	(231)
	—	—	(231)

Total	52	(86)	(265)

10.3 Uncertain tax positions

The Company operates in multiple jurisdictions with complex

legal and tax regulatory environments. In certain of these

jurisdictions, ArcelorMittal has taken income tax positions that

management believes are supportable and are intended to

withstand challenge by tax authorities. Some of these positions

are inherently uncertain and include those relating to transfer

pricing matters and the interpretation of income tax laws

applied in complex transactions. The Company periodically

reassesses its tax positions. Changes to the financial

statement recognition, measurement and disclosure of tax

positions are based on management’s best judgment given any

changes in the facts, circumstances, information available and

applicable tax laws. Considering all available information and

the history of resolving income tax uncertainties, the Company

believes that the ultimate resolution of such matters will not

have a material effect on the Company’s financial position,

statements of operations or cash flows beyond the income tax

contingencies recorded as of the reporting date. (see notes 9.2

and 9.3). 10.4 Deferred tax assets and liabilities

The origin of the deferred tax assets and liabilities is as follows:


	Assets		Liabilities		Net
	2025	2024	2025	2024	2025	2024
Intangible assets	26	21	(265)	(494)	(239)	(473)
Property, plant and equipment	109	289	(3,978)	(3,599)	(3,869)	(3,310)
Inventories	164	200	(75)	(60)	89	140
Financial instruments	70	23	(42)	(82)	28	(59)
Other assets	149	374	(634)	(652)	(485)	(278)
Provisions	784	692	(677)	(557)	107	135
Other liabilities	628	584	(137)	(109)	491	475
Tax losses and other tax benefits carried forward	10,137	9,733	—	—	10,137	9,733
Tax credits carried forward	307	241	—	—	307	241
Deferred tax assets (liabilities)	12,374	12,157	(5,808)	(5,553)	6,566	6,604
Deferred tax assets					8,860	8,942
Deferred tax liabilities					(2,294)	(2,338)

Deferred tax assets recognized by the Company as of December 31, 2025 included the following:


	Gross amount	Total deferred tax assets	Recognized deferred tax assets	Unrecognized deferred tax assets
Tax losses and other tax benefits carried forward	157,279	37,557	10,137	27,420
Tax credits carried forward	769	769	307	462
Other temporary differences	16,644	3,989	1,930	2,059
Total		42,315	12,374	29,941

Deferred tax assets recognized by the Company as of December 31, 2024 included the following:


	Gross amount	Total deferred tax assets	Recognized deferred tax assets	Unrecognized deferred tax assets
Tax losses and other tax benefits carried forward	150,155	35,888	9,733	26,155
Tax credits carried forward	646	646	241	405
Other temporary differences	15,025	3,553	2,183	1,370
Total		40,087	12,157	27,930

As of December 31, 2025, the majority of unrecognized

deferred tax assets relates to tax losses carried forward

attributable to various subsidiaries located in different

jurisdictions (primarily Brazil, Germany, Luxembourg, Spain

and South Africa) with different statutory tax rates. At each

reporting date, ArcelorMittal considers existing evidence, both

positive and negative, including the earnings history and

results of recent operations, reversals of deferred tax liabilities,

projected future taxable income, and planning strategies, that

could impact the view with regard to future realization of these

deferred tax assets.

The amount of the total deferred tax assets is the aggregate

amount of the various recognized and unrecognized deferred

tax assets at the various subsidiaries and not the result of a

computation with a given blended rate. The utilization of tax

losses carried forward is restricted to the taxable income of the

subsidiary or tax consolidation group to which it belongs. The

utilization of tax losses carried forward may also be restricted

by the character of the income, expiration dates and limitations

on the yearly use of tax losses against taxable income.

At December 31, 2025, the total amount of accumulated tax

losses in Luxembourg with respect to the ArcelorMittal S.A. tax

integration amounted to 133.4 billion, of which 35.0 billion is

considered realizable, resulting in the recognition of 8.4 billion

of deferred tax assets at the applicable income tax rate in

Luxembourg. At December 31, 2024, the total amount of

accumulated tax losses in Luxembourg with respect to the

main tax consolidation amounted to approximately 130.3

billion, of which 35.5 billion was considered realizable, resulting

in the recognition of 8.5 billion of deferred tax assets at the

applicable income tax rate in Luxembourg. Under the

Luxembourg tax legislation, tax losses generated before 2017

can be carried forward indefinitely and are not subject to any

specific yearly loss utilization limitations. The tax losses carried

forward relate primarily to tax deductible write-down charges

taken on investments in shares of consolidated subsidiaries

recorded by certain of ArcelorMittal’s holding companies in

Luxembourg. Of the total tax losses carried forward, 74.8 billion

may be subject to recapture in the future if the write-downs that

caused them are reversed creating taxable income unless the

Company crystallizes them through sales or other

organizational restructuring activities.

The Company believes that it is probable that sufficient future

taxable profits will be generated to support the recognized

deferred tax asset for tax losses carried forward in

Luxembourg. As part of its recoverability assessment the

Company has taken into account (i) its most recent forecast

approved by management and the Board of Directors, (ii) the

likelihood that the factors that have contributed to past losses

in Luxembourg will not recur, (iii) the fact that ArcelorMittal in

Luxembourg is the main provider of funding to the Company’s

consolidated subsidiaries, leading to significant amounts of

taxable interest income on outstanding and future loans as

updated based on most recent funding strategy, (iv) the

expected level of interest expenses in Luxembourg driven by

the Group net debt level, (v) the industrial franchise agreement

whereby ArcelorMittal S.A. licenses its business model for

manufacturing, processing and distributing steel to group

subsidiaries, and (vi) other significant and reliable sources of

operational income earned from ArcelorMittal’s European and

worldwide operating subsidiaries for centralized distribution

and procurement activities performed in Luxembourg. The

Company has also considered the implications of the net-zero

path and its carbon emissions intensity reduction targets on its

future taxable profits expectations in relation to the existing

business models and the potential future financing of such

projects, resulting in no major impact on the estimated level of

future taxable profit. In performing the assessment, the

Company estimates at which point in time its earnings

projections are no longer reliable, and thus taxable profits are

no longer probable. Accordingly, the Company has established

consistent forecast periods for its different income streams for

estimating probable future taxable profits, against which the

unused tax losses can be utilized in Luxembourg.

At December 31, 2025, based upon the level of historical

taxable income and projections for future taxable income over

the periods in which the deductible temporary differences are

anticipated to reverse, management believes it is probable that

ArcelorMittal will realize the benefits of the recognized deferred

tax assets of 8.9 billion. The amount of future taxable income

required to be generated by ArcelorMittal’s subsidiaries to

utilize the deferred tax assets of 8.9 billion is at least 38.9

billion. Historically, the Company has been able to generate

sufficient taxable income and believes that it will generate

sufficient levels of taxable income in the coming years to allow

the Company to utilize tax benefits associated with tax losses

carried forward and other deferred tax assets that have been

recognized in its consolidated financial statements. Where the

Company has had a history of recent losses, it relied on

convincing other evidence such as the character of (historical)

losses and planning opportunities to support the deferred tax

assets recognized.

As of December 31, 2025, ArcelorMittal recorded 117 of

deferred income tax liabilities in respect of deferred taxation

that would arise if temporary differences on investments in

subsidiaries, associates and interests in joint ventures were to

be realized in the foreseeable future as compared to 132 as of

December 31, 2024. No deferred tax liability has been

recognized in respect of other temporary differences on

investments in subsidiaries, associates and interests in joint

ventures because the Company is able to control the timing of

the reversal of the temporary difference and it is probable that

such differences will not reverse in the foreseeable future. The

amount of these unrecognized deferred tax liabilities was 923

at December 31, 2025 (898 at December 31, 2024).

10.5 Tax losses, tax credits and other tax benefits carried

forward

At December 31, 2025, the Company had total estimated tax

losses carried forward and other tax benefits of 157.3 billion.

This includes net operating losses and other tax benefits of

27.1 billion primarily related to subsidiaries in the Basque

Country in Spain, Luxembourg, Mexico, Poland and the United

States which expire as follows:


Year expiring	Recognized	Unrecognized	Total
2026	1	48	49
2027	3	201	204
2028	23	261	284
2029	30	102	132
2030	118	110	228
2031 - 2046	1,181	24,986	26,167
Total	1,356	25,708	27,064

The remaining tax losses carried forward and other tax benefits

for an amount of 130.2 billion (of which 41.0 billion are

recognized and 89.3 billion are unrecognized) are carried

forward for unlimited period of time and primarily relate to the

Company’s operations in Brazil, France, Germany,

Luxembourg, and Spain.

At December 31, 2025, the Company also had total estimated

tax credits carried forward of 769.

Such amount includes tax credits of 517 (of which 106

recognized and 411 unrecognized) primarily attributable to

subsidiaries in the Basque country in Spain and Luxembourg

which expire as follows:


Year expiring	Recognized	Unrecognized	Total
2026	—	1	1
2027	—	1	1
2028	—	1	1
2029	—	1	1
2030	—	1	1
2031 - 2046	106	406	512
Total	106	411	517

The remaining tax credits for an amount of 252 of which 201

are recognized and 51 are unrecognized) are indefinite and

primarily attributable to the Company’s operations in Brazil, the

Netherlands, Spain and the United States.

Tax losses, tax credits and other tax benefits carried forward

are denominated in the currency of the countries in which the

respective subsidiaries are located and operate, except for

Luxembourg where the tax losses are mainly denominated in

U.S. dollar. Fluctuations in currency exchange rates could

impact the U.S. dollar equivalent value of these tax losses

carried forward in future years.