Syntegon Technology Limited and Kliklok International Limited - UK TAX STRATEGY (published 22/12/2023)

Scope

This strategy applies to Syntegon Technology Limited and Kliklok International Limited (the “UK Companies") in accordance with paragraph 19 of Schedule 19 to the Finance Act 2016. The following information applies in relation to the UK tax affairs of the UK Companies. The UK Companies regard this publication as complying with their duty under paragraph 19(2) Schedule 19 Finance Act 2016 for the financial year ending 31 December 2024.

This strategy applies from the date of publication until it is superseded. References to “UK Taxation” are to the taxes and duties set out in paragraph 15(1) of the Schedule. This includes Income Tax, Corporation Tax, PAYE, NIC, VAT, Insurance Premium Tax, Stamp Duty and Stamp Duty Land Tax. References to “tax”, “taxes” or “taxation” are to UK Taxation and to all corresponding worldwide taxes and similar duties in respect of which the UK Companies have legal responsibilities.


Aim

The UK Companies, in line with the overall Syntegon Group’s Global Code of Conduct, are committed to full compliance with all statutory obligations and full disclosure to relevant tax authorities. The Syntegon Group’s tax affairs are managed in a way which considers the wider corporate reputation in line with the UK Companies overall high standards of governance.


Risk Management and Governance

It is the UK Companies’ policy to comply with all applicable UK tax legislation, regulations and reporting requirements. The UK Companies manage UK tax affairs through their established internal governance framework. Tax declaration and compliance tax work relating to UK taxes as well as ad-hoc tax advice have been outsourced to a high extent to external tax advisors. Furthermore, the UK Companies ensure that experienced personnel are involved in identifying, assessing, and managing all UK tax risks so that they are accounted for appropriately. Day-to-day management of UK tax affairs is handled by the Financial Controllers who report on UK tax matters through the international finance team to Syntegon Group´s Head of Tax.


UK Tax Planning and Tax Risk

The Syntegon Group applies arm’s-length principles in the pricing of all intra-group transactions of goods and services and financial transactions in accordance with Organisation for Economic Co-operation and Development (OECD) guidelines and local laws. In the context of the Syntegon Group’s global business, the UK business is relatively small and the taxable profit arising to the UK entities commensurate with Syntegon Group’s activities undertaken in the UK.

In accordance with the UK Companies values and internal financial risk management approach, the UK Companies seek to take advantage of available tax incentives, reliefs, and exemptions in line with, and in the spirit of, tax legislation. However, the UK Companies do not engage in artificial or aggressive tax planning.

The level of risk which the UK Companies accept in relation to UK taxation is consistent with its overall objective of achieving certainty in the Syntegon Group’s tax affairs. At all times the UK Companies seek to comply fully with their regulatory and other obligations and to act in a way which upholds their reputation as a responsible corporate citizen and therefore adopt a low-risk approach when considering their UK tax affairs.


Working with HM Revenue & Customs (“HMRC”)

The UK Companies maintain a collaborative and transparent relationship with HMRC in relation to tax compliance, strategy, risks and significant transactions. The UK Companies are committed to make full and accurate disclosures in tax returns and in correspondence with HMRC.

However, in the event of any inadvertent errors in submissions made to HMRC, the UK Companies ensure prompt disclosure as soon as reasonably practicable after they have been identified.