This document sets out the UK tax strategy of the A.Schulman UK group companies. A. Schulman has a low appetite towards tax risk. We are committed to full compliance with our tax obligations, paying the right amount of tax at the right time.
This tax strategy is published in accordance with the requirements of Schedule 19, Finance Act 2016.
Within A. Schulman, tax is managed by an integrated team of tax specialists reporting to the Global Chief Financial Officer. They deal with Tax Compliance, Tax Accounting & Reporting, Indirect Tax, Corporate Tax, and Transfer Pricing.
Local risks are managed within the European region via the in-house EMEA tax team which considers the specific tax risks arising in the UK and determines how to mitigate those risks. The EMEA team regularly consults with the Global Director of Tax. In function of SOX regulations, a detailed tax risk matrix has been prepared and appropriate tax controls are in place and regularly tested.
The Global Director of Tax meets the Board of Directors formally every quarter to discuss tax issues that are relevant to the worldwide group including the UK. He presents details of relevant worldwide tax developments, tax audits and tax controversy. This meeting will also be attended by the Group’s General Counsel and the Statutory Auditors.
Tax risk appetite and attitude to planning
In operating our tax risk management and governance processes, A. Schulman has a low appetite towards tax risk.
In accordance with the group’s values, our approach is not to engage in tax planning that does not support genuine commercial activity. We do not seek to structure transactions in ways that give tax results inconsistent with their underlying economic consequences. We aim to ensure that our tax position in any planning activity is consistent with the spirit as well as the letter of tax law and we will take external advice to confirm this where there is any uncertainty.
We do not promote tax avoidance or aggressive tax planning arrangements to our customers or to other parties. When facing tax issues or expenses, internal and/or external resources are used to ensure the correct tax treatment is adopted. The Tax Department will meet with the appropriate people (i.e., internal business owners, Legal, Treasury, Accounting, Budget, Human Resources, and IT personnel and, if necessary, outside auditors and tax advisers) to determine the viability of any tax position adopted and to assess any non-tax risks. The Tax Department assesses tax risks, utilizing outside counsel when appropriate. Memoranda, presentation and computational materials are developed throughout the process. If necessary, an opinion of outside counsel is requested.
We remunerate our colleagues such that the proper amounts of tax and national insurance contributions are paid on the rewards of their employment.
Relationship with HMRC
We engage with HMRC openly and constructively, based on mutual trust and co-operative compliance. We feel this is the best way to ensure that we pay the right tax at the right time and to maintain a good working relationship. Where appropriate and possible we will engage with HMRC on a real time basis in any areas of material uncertainty, so as to minimise our tax risk and to provide greater certainty for both parties in advance of formal tax filings.
Prevention of the Facilitation of Tax Evasion
A. Schulman does not tolerate any activities which criminally facilitate tax evasion in either the UK or overseas jurisdictions. We are committed to preventing the facilitation of tax evasion by associated individuals or businesses anywhere within our operations. We do this through developing prevention procedures, carrying out regular due diligence and risk assessments of our activities, and creating awareness and a culture of compliance.
Dated: April 25, 2018