UDG Healthcare – UK Tax Strategy

Scope

UDG Healthcare UK (Holdco) Limited, a limited liability company registered in England and Wales, is a direct wholly owned subsidiary of UDG Healthcare plc.

This strategy applies to UDG Healthcare UK (Holdco) Limited and its UK subsidiary companies in accordance with paragraph 19 of Schedule 19 to the Finance Act 2016 (‘the Schedule’).

In this strategy, any references to ‘UDG’ or the ‘Group’ mean all of these entities. By publishing this strategy on the investor relations section of the UDG Healthcare plc corporate website UDG and the Group complies with the requirements of the Schedule.

References to ‘UK Taxation’ are to the taxes set forth in paragraph 15 (1) of the Schedule which includes Corporation Tax, PAYE, NIC and VAT while references to ‘tax’, ‘taxes’ or ‘taxation’ are references to UK Taxation.

Commitment to compliance

UDG is committed to compliance with all statutory obligations and full disclosure to the tax authorities. Compliance for UDG means, paying the right amount of tax in the right place at the right time. It involves disclosing all relevant facts and circumstances to HMRC and claiming reliefs and incentives where available.

UDG’s tax affairs are managed on a day to day basis in a manner which takes into account the Group’s wider corporate responsibility and reputation and is aligned to UDG’s commitment to the highest standards of corporate governance.

Our approach to risk management and governance arrangements in relation to taxation

Ultimate responsibility for UDG’s tax risk management and compliance rests with the Chief Financial Officer with oversight of the UDG Healthcare plc Board of Directors and the Audit Committee.

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 and support from the UDG Healthcare plc tax department is available to employees who manage or process matters which have tax implications.

The management of tax risk and tax compliance is supported by internal control frameworks which govern the commercial operations of UDG and are subject to regular reviews by the UDG Healthcare plc internal audit department.

Responsible attitude to tax planning and arranging tax affairs

UDG carefully manages the tax risks and costs inherent in its commercial transactions, in the same way as any other cost. When entering into commercial transactions, UDG seeks to take advantage of available tax incentives, reliefs and exemptions in line with, and in the spirit of, the relevant tax legislation. UDG does not undertake tax planning unrelated to such commercial transactions.

Reliance is placed upon external tax advisors where there is need for specialist guidance and support, for example benchmarking analysis to support transfer pricing arrangements and corporate restructurings.

The level of tax risk that UDG  is prepared to accept

The level of risk that UDG accepts in relation to taxation is consistent with the overall objective of achieving as much certainty as possible with respect to the Group’s tax affairs.  At all times the Group seeks to comply fully with its regulatory and other obligations and to act in a manner consistent with the UDG Healthcare plc commitment to best practice in corporate governance and responsible corporate citizenship.

In relation to any specific issue or transaction, the Chief Financial Officer with oversight from the Board of Directors of UDG Healthcare plc 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. The Group does not operate pre-defined limits as to the amount for acceptable tax risk; it is judged on an issue by issue basis.

Part of the assessment of risk of any transaction includes the likely HMRC view of the tax outcome and the potential impact on the Group’s ongoing relationship with HMRC.

Relationship with HMRC

UDG seeks to have a transparent and constructive relationship with HMRC through regular meetings and communications in respect of developments in the Group’s business, current, future and retrospective tax risks, and interpretation of the law relation to all relevant taxes.

UDG ensures that HMRC is kept aware of significant transactions and changes in the Group’s business and seeks to discuss any related tax issues as soon as possible.  When submitting tax computations and returns to HMRC, the Group 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 and corrected as soon as is reasonably practicable after they are identified.