March 31, 2020
TDK UK Limited (registered address: Bridge House, Brants Bridge, Bracknell, Berkshire RG12 9BG, United Kingdom) and its direct parent company, TDK Europe GmbH (registered address: Rosenheimerstr. 141e, 81671 Munich, Germany) are part of the global TDK Group, comprising TDK Corporation (registered address: 2-5-1 Nihonbashi, Chuo-ku, Tokyo, 103-6128, Japan) and all of its controlled subsidiaries. TDK UK Limited’s tax strategy, prepared in accordance with Part 2 of Schedule 19 to the Finance Act 2016 (the “Schedule”), is aligned with the TDK Groups’ Global Tax Policy (available here).
This strategy applies from the date of publication until it is superseded.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 TDK UK Limited has legal responsibilities.
TDK UK Limited is committed to full compliance with all statutory obligations and full disclosure to relevant tax authorities. The company’s tax affairs are managed in a way which takes into account the company and TDK Group’s wider corporate reputation and overall high standards of governance.
Corporate governance of TDK Group relevant to taxes is embedded within its overall governance system. The system provides a framework for compliance of applicable tax laws and regulations, minimisation of tax risks, maximisation of corporate value, and growth of the group. The corporate governance of the TDK Group relevant to taxes is executed under the responsibility of the CFO of the group who delegates certain portions to subgroup tax departments and persons in charge of taxes at each group entity. Responsibility for TDK UK Limited’s tax strategy and compliance rests with the company’s Board of Directors. Day-to-day management of TDK UK Limited’s tax affairs is delegated to the company’s Managing Director, who is supported by a finance team that is staffed with appropriately qualified individuals. The Board ensures that the tax strategy is one of the factors considered in all significant investments and business decisions taken.
TDK UK Limited operates a system of tax risk assessment and controls as a component of the overall internal control framework applicable to the TDK Group’s financial reporting system.
It 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 outside the finance team who manage or process matters which have tax implications. Advice is sought from the TDK Group tax function and external advisers where appropriate, including where uncertainty or significant transactions exist.
TDK UK Limited manages tax risks to ensure compliance with legal requirements in a manner which ensures payment of the right amount of tax. When entering into commercial transactions, TDK UK Limited seeks to utilise available tax incentives, reliefs and exemptions in line with, and in the spirit of, tax legislation. It does not implement artificial tax avoidance structures or undertake tax planning unrelated to commercial transactions. The level of risk which TDK UK Limited accepts in relation to UK taxation is consistent with its overall objective of achieving certainty in its tax affairs, as well as the tax affairs of the wider TDK Group. At all times it 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, that 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.
TDK UK Limited seeks to have a transparent and constructive relationship with HMRC. All significant tax risks are identified at the time of preparation of tax returns and when these are submitted to HMRC, it discloses all relevant facts and identifies any transactions of issues where it considered 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. All dealings with HMRC are undertaken in a timely and collaborative manner.