Belcan Group UK Tax Strategy

Introduction

This document summarizes Belcan International Limited and worldwide subsidiaries’ (together “Belcan Group”) policy and approach to conducting United Kingdom (“UK”) tax affairs and managing tax risk.  This document has been prepared pursuant to Paragraph 19 (2), Schedule 19 of the UK Finance Act 2016 and approved by Belcan International Limited’s Board of Directors.  This document is reviewed annually and significant amendments are approved by the Belcan International Limited’s Board of Directors.  Belcan Group’s publication of its UK tax strategy is applicable to all Belcan UK companies.

Compliance with UK tax laws, rules and regulations

Belcan Group respects and obeys the laws, rules and regulations for all jurisdictions where Belcan Group operates.  This is in alignment with the Belcan Code of Conduct.  As such, Belcan Group is committed to observing and complying with all applicable UK tax laws, rules and regulations.  Belcan Group is committed to timely payment of taxes legally due in the UK.

Approach of Belcan Group to governance and risk management of UK tax matters

Belcan Group has established internal financial policies requiring its UK businesses to comply with all applicable UK tax laws. All relevant Belcan employees from the board of directors, the group finance director and below are tasked with following the process to ensure these policies are actioned in a timely and accurate manner.  Additionally, Belcan Group’s implementation and interpretation of UK tax matters are reviewed by external financial auditors and other tax advisors.

Attitude of Belcan Group toward UK tax planning 

Belcan Group does not engage in artificial tax arrangements.  Belcan Group UK tax planning supports UK commercial strategies and economic activities.  Transactions between Belcan Group companies are mostly conducted on an arm’s-length basis, and in accordance with UK tax laws and with the Belcan code of conduct.  Where certain transactions are not at arms’ length, such as the treatment of intercompany balances where no interest is charged, this does not negatively impact the tax liability from the perspective of HMRC. Professional external advice is sought when needed, for matters which require technical guidance or opinion such as, growth through acquisitions. We do not ask our business partners to do anything which helps them to evade tax. We raise invoices and other contractual documents which are true to the agreed commercial situation and do not include any false information. Any transactions with significant financial or reputational risk requires the approval of the Belcan group’s senior management.

Level of risk Belcan Group has in relation to UK taxation

Belcan Group’s UK tax planning strategies are deployed when it is more likely than not that the tax positions will be sustained upon audit.  Belcan Group assesses UK tax risk on an ongoing basis. Where transactions are complex or the tax law is uncertain, external advice is sought from expert advisors and tax authorities to achieve certainty.  Belcan Group’s external financial auditors also play an active role in reviewing the tax implications of transactions as they are implemented.

Approach to Her Majesty’s Revenue and Customs (“HMRC”)

Belcan Group is committed to seek, develop and promote a professional, collaborative, open and transparent relationship with HMRC through compliance with tax laws and regulation stipulated. We engage in a timely dialogue with HMRC to respond to queries and information requests to ensure that HMRC is aware of how issues are progressing. Belcan Group makes appropriate disclosures in tax returns, reports and correspondence submitted to HMRC and is committed to paying all tax liabilities in a timely manner.

This Tax Strategy relates to the Financial Year ending Dec 2021