Purpose of this document
This document sets out the tax policy of the Zetes Group in relation to UK taxation regulations. ‘Zetes Group’ and ‘Group’ refer to the worldwide group headed by Zetes Industries, Belgium.
This policy applies to all Zetes Group companies that have a UK presence (hereinafter the ‘UK Group’).
The publication of this policy is regarded as complying with the requirements of Part 2 Schedule 19 Finance Act 2016 in relation to the period ending 31 March 2018.
Overview of the Zetes Group in the UK
The Zetes Group is the European leader in design, development and implementation of integrated automatic identification solutions for goods and people.
The Zetes Group currently has a limited number of entities in the UK:
- one operational subsidiary,
- and several dormant companies.
Operational entities are headed by autonomous Management Teams. The Management Team is responsible for ensuring its own tax compliance in the country in which it operates, subject to following mandatory group policies and with appropriate oversight from senior management in Belgium and in the local territory.
Approach of UK Group to risk management and governance arrangements in relation to UK taxation
The UK Group is committed to complying with all tax laws in the UK and overseas. The Group views compliance with all laws, regulations and business ethics in its business activities as essential.
The Board of Zetes Industries oversees European tax affairs of the Zetes Group, including UK tax affairs. The Chief Financial Officer of Zetes Industries is the owner of this policy document, which has been prepared in conjunction with the Corporate Finance Department and the local management of each UK Group company.
This policy complements existing internal tax policies and procedures at global and local levels.
UK tax governance is supported by:
- the Corporate Finance Department based in Belgium, which advises and supports all UK Group businesses on UK tax obligations and monitors local tax compliance, and
- local management of each UK Group entity, which is required to maintain local tax compliance and report any potential tax issues to the Corporate Finance Department based in Belgium.
Although there is no prescriptive level of ‘acceptable’ UK tax risk for internal governance purposes, the UK Group’s appetite for tax risk is considered to be low.
UK tax risks are identified and monitored by the Head of Finance of each Group company or branch. Any significant UK tax risks are reviewed periodically by the Corporate Finance Department and reported on a regular basis to the Zetes Board of Directors.
Each local entity monitors its own accounting controls and these can be subject to formal internal reviews by the Corporate Finance Department.
Attitude of the UK Group towards tax planning and the acceptable level of risk
Every UK Group entity as well as every Zetes employee is expected to adhere to the Zetes Code of Business Conduct and Ethics, which emphasises the high ethical, moral and legal standards Zetes Group set up to conduct business. The tax matters within the Zetes Group are required to be managed in accordance with these values and policies.
At all times the UK Group 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.
As noted above, the UK Group is considered to have a low appetite for tax risk.
The UK Group will seek to utilise all tax incentives and reliefs available under UK domestic legislation, European law and other international instruments to which it is entitled, in compliance with the law and respecting the underlying policy intention.
In addition, the UK Group will seek to minimise double taxation (payment of tax on the same profits in more than one country) by entering into Mutual Agreement Procedures between tax authorities whenever it is economic to do so.
Any business planning undertaken by the UK Group is aligned to commercial substance. Business intentions are the key driver for any planning that has tax implications. The UK Group does not enter into transactions without any commercial substance in order to achieve a tax objective.
Illegal tax evasion is fraudulent and not tolerated, and any employee found to be engaged in, or facilitating, tax evasion will face disciplinary action.
The UK Group may seek an opinion from a tax adviser in instances of material business restructurings, tax law changes or lack of clarity regarding the appropriate interpretation of tax law, to manage its tax risk. In addition, in instances of merger and acquisition activity, HMRC would be contacted in advance in case of uncertainty, if this is appropriate.
Approach of the UK Group towards its dealings with HM Revenue & Customs (‘HMRC’)
The UK Group will always maintain an open, honest, transparent and constructive relationship with HMRC in respect of developments in Zetes UK’s businesses.
The UK Group seeks to discuss any tax issues arising at an early stage. When submitting tax computations and returns to HMRC, the UK Group will disclose all relevant facts and identifies any transactions or issues where it considers that there is potential for the tax treatment to be uncertain.
The UK Group will respond to queries from HMRC in a timely and complete manner. Any inadvertent errors in submissions made to HMRC are fully disclosed as soon as reasonably practicable after they are identified.