How Ultra approaches tax

We incur many different tax liabilities around the world approaching £50m annually

We contribute via corporate income taxes, social security contributions, business rates, customs duties and numerous other taxes and levies. In addition, we devote significant effort on behalf of HM Revenue and Customs and overseas tax authorities to administering and collecting indirect taxes such as VAT from our customers and employment taxes for over 4,000 employees globally.

Governance

Our business finance teams are responsible for reporting and paying many of the tax liabilities we are subject to and most of the tax we collect on behalf of tax authorities. The tax function lead the execution of our tax strategy, advise on tax policies and procedures, provide guidance and training on best practices and are responsible for UK and US corporate income taxes.  The Executive Team and the Board set the strategic direction for the tax function and together with the Audit Committee review key tax judgements.

Ultra’s corporate ethics policy requires all employees, businesses and third parties, who act on Ultra’s behalf, to comply fully with the Group’s standards of business ethics and with applicable laws and regulations. 

Strategic Direction

We aim to maintain a sustainable and competitive overall tax position for the Group through astutely and ethically facilitating our ONE Ultra strategy and focus on:

  • supporting our investments in technology globally with available local tax incentives;
  • providing our businesses with commercial and timely tax advice; and
  • leveraging our capital expenditure by deploying approved tax-efficient financing arrangements.

We are also committed to continuously improving our tax processes and procedures, simplifying our operational structure for tax and maintaining high standards of responsible tax management. 

Tax risk management

Ultra manages tax risks under the same risk management framework as other risks the Group faces. Our approach to risk management is explained in some detail in the strategic report published with the Group’s annual accounts. In the UK, we reassess annually whether we have appropriate tax accounting arrangements, to ensure the integrity of our tax returns and timely and accurate tax payments, as required by the Senior Accounting Officer (“SAO”) legislation. We maintain a tax function of suitably qualified and experienced professionals to manage our tax affairs and they are supported by external advisers as necessary.

Tax planning

Ultra has to take account of the impact of tax on stakeholder value. The tax regimes we are subject to are complex and present significant scope for both adverse tax consequences and tax advantages. When undertaking substantive business transactions, such as new investments and divestments, it is necessary to plan to optimise tax in a way that is consistent with those commercial transactions and our business objectives, to sustain stakeholder value and commercial competitiveness. In managing our tax affairs, we seek to minimise the risks of uncertainty or disputes with tax authorities and do not  engage in artificial arrangements.

Relationship with the tax authorities

We aim to maintain relationships with tax authorities that are constructive and based on mutual respect. We cooperate fully with audits and enquiries and wherever possible work collaboratively to resolve disputes and expedite early agreement of issues and uncertainties. We expect our external advisers to take the same approach.  Where necessary, we are prepared to defend our legitimately filed tax positions through judicial resolution.

This document was approved by the Board on 17 June 2021, has applied throughout 2021 and remains in force as at September 2021. The publication of our tax strategy is required by Schedule 19 Finance Act 2016.

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