September 2020

SCOPE

This strategy applies to LEDVANCE Ltd, a limited company registered in England and Wales and the only UK subsidiary of the LEDVANCE Group. This strategy has been published in accordance with paragraph 16(4) of Schedule 19 to the Finance Act 2016.
This strategy applies from the date of publication until it is superseded.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 which include Income Tax, Corporation Tax, PAYE, NIC, VAT, Insurance Premium Tax, 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 LEDVANCE Ltd has legal responsibilities.

AIM

LEDVANCE Ltd is committed to full compliance with all statutory obligations and full disclosure to relevant tax authorities. LEDVANCE Ltd’s tax affairs are managed in a way which takes into account the group’s wider corporate reputation in line with LEDVANCE Ltd’s overall high standards of governance.

GOVERNANCE IN RELATION TO UK TAXATION

• Ultimate responsibility for LEDVANCE Ltd’s tax strategy and  compliance rests with the Board of LEDVANCE Ltd;
• Executive management of the group is delegated by the Board to the Chief Financial Officer (‘CFO’);
• The Chief Financial Officer (‘CFO’) is the Board member with executive responsibility for tax matters;
• Day-to-day management of LEDVANCE Ltd’s tax affairs is delegated to LEDVANCE Ltd’s Head of Tax, who reports to the CFO;
• The Finance and Tax teams are staffed with appropriately qualified individuals;
• The Board ensures that LEDVANCE Ltd’s tax strategy is one of the factors considered in all investments and significant business decisions taken;
• The Head of Tax reports to the Board on LEDVANCE Ltd’s tax affairs and risks during the year.
   

RISK MANAGEMENT

• LEDVANCE Ltd operates a system of tax risk assessment and controls as a component of the overall internal control framework applicable to the group’s financial reporting system;
• LEDVANCE Ltd seeks to reduce the level of tax risk arising from its operations as far as is reasonably practicable by ensuring that reasonable care is applied in relation to all processes which could materially affect its compliance with its tax obligations;
• Processes relating to different taxes are allocated to appropriate process owners, who carry out a review of activities and processes to identify key risks and mitigating controls in place. These key risks are monitored for business and legislative changes which may impact them and changes to processes or controls are made when required;
• Appropriate training is carried out for staff who manage or process matters which have tax implications;
• Advice is sought from external advisers where appropriate.
   

ATTITUDE TOWARDS TAX PLANNING AND LEVEL OF RISK

LEDVANCE Ltd manages risks to ensure compliance with legal requirements in a manner which ensures payment of the right amount of tax.

When entering into commercial transactions, LEDVANCE Ltd seeks to take advantage of available tax incentives, reliefs and exemptions in line with, and in the spirit of, tax legislation. LEDVANCE Ltd does not undertake tax planning unrelated to such commercial transactions.

The level of risk which LEDVANCE Ltd accepts in relation to UK taxation is consistent with its overall objective of achieving certainty in the group’s tax affairs. At all times LEDVANCE Ltd seeks to comply fully with its regulatory and other obligations and to act in a way which upholds its reputation as a responsible corporate citizen. In relation to any specific issue or transaction, the Board is ultimately responsible for identifying the risks, including tax risks, which need to be addressed and for determining what actions should be taken to manage those risks, having regard to the materiality of the amounts and obligations in question.

RELATIONSHIP WITH HMRC

LEDVANCE Ltd seeks to have a transparent relationship with HMRC ensuring that relevant information in respect of developments in LEDVANCE Ltd’s business, current, future and retrospective tax risks, and interpretation of the law in relation to all relevant taxes are made available as and when required.

LEDVANCE Ltd ensures that HMRC is kept aware of significant transactions and changes in the business. When submitting tax computations and returns to HMRC, LEDVANCE Ltd discloses all relevant facts and identifies any transactions or issues where it considers that there is potential for the tax treatment to be uncertain.

Any inadvertent errors in submissions made to HMRC are fully disclosed as soon as reasonably practicable after they are identified.