UK Tax Strategy Statement

General Principles

• It is the policy of the Group to comply with all applicable tax laws and regulations, as well as with international treaties and OECD international tax guidelines
• The Group is committed to an open and transparent relationship and dialogue with the appropriate tax authorities

Tax Governance

The Group’s business strategy is set by the Chief Executive Officer in collaboration with the Chief Financial Officer, executive team and Board of Directors.  The Group’s tax affairs are managed by the Vice President, Tax with the aim of maintaining a principled and sustainable tax strategy that has strong commercial merit and is closely aligned with the Group’s business strategy.  All significant corporate actions, both business structures and related tax implications, are approved by the Chief Financial Officer. At a UK subsidiary level, the UK CFO and Finance Director ensure that the Group’s tax strategy and policies are implemented and adhered to, and that the UK management team are kept appraised of developments in the legislative environment. The Group employs suitably qualified personnel to manage its day-to-day UK tax affairs, in co-ordination with its external tax advisors.

Risk Management

The Group recognises that there is an inherent risk involved in managing its tax affairs due to the size, complexity and dynamic nature of its operations. The Group’s approach to mitigating these risks is based on an assessment of the likelihood and impact of their occurrence, on a case by case basis. Process controls and review frameworks are monitored and updated in line with this principle. In addition, the finance and tax teams provide partnering support across the business as an integral part of the commercial decision-making process. External expert tax advice is called upon to help mitigate tax uncertainty.

Attitude to Tax Planning

The Group’s commercial needs are its key focus and any tax planning is undertaken in this context and in response to specific business requirements.  The Group makes use of available tax incentives where applicable. The Group also uses external advisors to support its activities to ensure compliance with applicable tax laws and regulations.

Approach to Dealings with HMRC

The Group is committed to the following principles when dealing with HMRC:

• Ensuring all interactions with HMRC are conducted in a transparent and professional manner.
• Taking a proactive approach where issues are identified, and seeking to work collaboratively to resolve.
• Ensuring that returns are made and queries responded to on a timely and open basis.

This UK Tax Strategy Statement is being published to satisfy Schedule 19 of the UK Finance Act 2016, for our financial year ending in June 2018.