Tax strategy UK
Uponor Ltd regards the publication of this tax strategy as complying with its duty under paragraph 22(2) of Schedule 19 of the Finance Act 2016 to publish its tax strategy in the financial year ending 31 December 2023. This Tax Strategy is not designed to be an operational manual with detailed instructions of the execution of the processes. The scope of this Tax Strategy covers:
• All corporate income taxes;
• Indirect taxes (VAT, Stamp Duty)
• Customs duties
• Employment taxes (PAYE / National Insurance)
• Excise taxes (e.g. plastic tax)
• Property tax
• Other applicable tax matters
The Tax Strategy is approved by the CFO of Uponor Group.
Taking each of the requirements of paragraph 22 (2) of Schedule 19 in turn:
1. Approach of the UK company to risk management and governance arrangements in relation to UK taxation
1.1 Governance
Responsibility for Uponor Limited’s tax strategy, the supporting governance framework and management of tax risk ultimately sits with the Uponor Group Chief Financial Officer and Head of Group Tax. Day-to-day responsibility for each of these areas sits with the Finance team.
Uponor Limited’s tax strategy aligns with the Uponor Group's wider risk and control framework. Risks related to tax are considered by the Group Audit Committee on a regular basis.
1.2 Tax risk management
The Uponor Group operates presently in 30 countries and manages its tax risks as follows:
1.2.1 Tax compliance and reporting risks
The Uponor Group is committed to full compliance with all statutory obligations. Uponor Limited’s target is to comply with the applicable tax rules in the UK for all the tax filing, tax reporting and tax payment obligations. The Uponor Group is committed to responding to all tax authorities’ requests in a timely manner.
1.2.2 Transactional risks
The Uponor Group applies the OECD standards in cross-border transactions and ensure that the transfer pricing is according to “arm’s length principle”. Uponor Ltd does not engage in artificial tax arrangements and ensures that the outcomes are consistent with commercial realities.
With the tax landscape constantly changing, the tax affairs and tax risk management procedures are regularly reviewed to ensure that processes and measures are up-to-date so that we are able to identify, assess, manage and mitigate tax risk.
1.2.3 Reputational risks
• The companies aim to manage tax risk in a similar way to any area of operational risk across the Group. The business is supported by oversight functions, including Group Finance, Group Risk Management and Group Internal Audit
• Where appropriate, the companies look to engage with tax authorities to disclose and resolve issues, risks and uncertain tax positions. The subjective nature of global tax legislation means that it is often not possible to mitigate all known tax risks.
1.2.4 Applied risk mitigation rules are
• observe all applicable laws, rules and regulations, case law and disclosure requirements
• ensure that all decisions are taken at an appropriate level and supported with documentation evidencing the facts, conclusions and risks involved
• seek professional advice and opinions from independent external advisors in complex and uncertain tax matters and aim to certainty on tax positions.
2. Attitude of Uponor Limited to tax planning (so far as affecting UK taxation)
The Uponor Group considers the tax laws in the jurisdictions in which it operates. It seeks to be fully compliant with all tax laws and regulations of local tax authorities, and seeks to operate in a tax efficient manner as required by its shareholders. Uponor Ltd follows this approach.
The attitude to tax planning is to ensure compliance with all relevant and applicable tax laws, and pay all taxes as required by law. The finance and tax teams support the needs of the business in this respect.
3. Level of risk in relation to UK taxation that the Uponor Limited is prepared to accept
The Uponor Group’s tax risk appetite requires that, where tax law is unclear or subject to interpretation, its adopted tax position is at least more likely than not to be allowable under applicable tax laws. This approach applies to all companies in the group including Uponor Limited.
4. Approach of Uponor Limited towards dealings with HMRC
The Uponor Group seeks to comply with its tax filing, tax reporting and tax payment obligations globally. Accordingly, Uponor Limited is required to foster good relationships with HMRC, in particular the company will:
• Pro-actively manage its relationship with HMRC with the aim of minimising the risk of challenge, dispute or damage to its credibility
• Participate in any tax authority formal consultation process where it is expected that the matter under consultation will have a material impact on the company’s liability or the company’s tax compliance management