Tax Strategy

Introduction

Because of the worldwide nature of our business, Tigers Group (“Tigers” or “Group”) operates in twelve jurisdictions across the globe. It is important to the Group that we pay our fair share of tax where we operate.

At the same time, we operate on a globally competitive environment and we work to ensure that we pay tax only once on the same profits.

The commercial needs of Tigers are paramount and all transactions and associated tax planning will be undertaken with a business purpose in mind, or a commercial rationale.

Due consideration will be given to Tigers reputation as well as the legal and fiduciary duties of the Group’s directors and its employees.

Our tax strategy

We aim to pay the right amount of tax at the right time, on the profits we make, and in the countries where we create the value that generates those profits.

Accountability and governance

We ensure that we have the mechanisms in place to adhere to the tax principles set out in this Tax Code of Conduct.

We report to Tigers’ Board of Directors on tax strategy and governance. Tigers’ Board of Directors receives annual updates on the Group’s effective tax rate, tax provisions, key tax issues, and on compliance with our tax principles.

The finance team

The tax function forms part of the Tigers’ finance team. The team includes the head of Local Finance in each of the jurisdictions in which we operate and the Group Controller who assist with this. The team reports to the Group Chief Finance Officer (“CFO”). The heads of Local Finance are also responsible for corporate taxes (including national, federal, state and provincial taxes; indirect taxes (including customs duties, VAT, GST and sales taxes); employment taxes; and other taxes. “Other taxes” include services taxes, property taxes; local business taxes, social, church and educational taxes. Advice is sought by the team from external advisors whenever the necessary expertise is not available in-house.

Our tax principles – generally

With our tax strategy in mind, we therefore:

• Aim to observe in each country all applicable laws, regulations, practices and disclosure requirements;
• Seek openness, honesty and transparency in all our dealings with the tax authorities;
• Will not use contrived or abnormal tax structures that are intended for tax avoidance, have no commercial substance and do not meet the spirit of local or international law;
• Shall not use tax havens for tax avoidance purposes

Our tax principles – relating to tax compliance and tax risk management

Again, with our tax strategy in mind, we shall therefore:

• Aim to prepare and file all tax returns in the form specified and at the time required;
• Exercise the necessary judgement on tax sensitive items in each tax jurisdiction on a consistent basis;
• Aim to pay an appropriate amount of tax according to where value is created within the normal course of commercial activities. In this connection, we will ensure that the prices paid on transactions between companies in the Tigers Group are calculated using the “arm’s-length” principle.
• Prepare and retain the documentation required by the tax laws or which will be needed to answer any questions;
• Engage or employ suitably qualified tax professionals with the appropriate levels of expertise and understanding;
• Rely on expertise and information from other parts of the Tigers’ Group and from external advisors;
• Apply diligent professional care and judgement to arrive at well-reasoned conclusions;
• Ensure that all decisions are taken at an appropriate level and supported with documentation that evidences the facts, conclusions and risks involved in taking all tax positions in the tax returns that are filed;
• Seek certainty on tax positions that the Group adopts: but where tax law is unclear or uncertain or subject to interpretation, written advance confirmation, or clearances will be sought as permitted by local law and practice, and a risk assessment will be made where relevant.
• Defend tax positions taken in Tigers’ tax returns;
• Monitor changes in relevant tax law and practice and assess any consequences for Tigers with the aim of mitigating any adverse impact.
• Avoid reputational damage to the Group.

Our tax principles – additional tax risk management procedures for decision making

Tigers’ tax function must be involved in the planning, implementation and documentation for:

• All business or share acquisitions and disposals;
• All changes in corporate structure;
• All cross-border financing arrangements;
• All significant business transactions;
• All cross-border trading transactions;
• All significant new processes affecting tax.

The finance team in each affected jurisdiction should be included as part of this engagement.

Where any new cross-border intra group arrangements are being set up, the local tax function and head office must also be involved, and well in advance of any arrangements being put in place so that appropriate inter-company pricing can be designed and documented accordingly in accordance with transfer pricing strategy.

The appointed teams should consider the financial return; cash flow; profit and loss impact; financial risks, costs and benefits. The teams should also carry out a risk assessment; summarise these for Tigers and make their recommendations.

The authority to proceed or to abort will rest ultimately with the CFO, in particular, where there is a level of financial risk, or reputational damage involved.

Tax reporting procedures and provisions

The tax code of conduct requires that Tigers complies with all laws and disclosures and act with due professional care. To comply with these requirement the Group ensures the tax position as presented in the financial statements of the Group are completed with accuracy and completeness.

The financial statements will reflect all taxes based on earnings for the period that are reported as part of the tax charge and included in, or otherwise noted as forming part of the tax provision.

Absolute transparency is needed between the subsidiary companies and Group’s finance team to ensure appropriate accounting and disclosure decisions to facilitate external reporting and also accurate and complete briefing of the Group CFO.

The tax charge and provisioning decisions should reflect the most up to date information to ensure that the Group will have no significant adjustments to the actual tax charge or tax returns.

Local companies should:

• Calculate all tax charges in accordance with the Group’s accounting policy;
• Provide timely, complete and accurate tax information packs in accordance with reporting instructions from the Group;
• Share relevant information in update calls with the Group, or in accordance with the reporting Group’s reporting instructions;
• Assist the Group with questions and clarifications required as part of the reporting process.
• Ensure all the tax deliverables and corresponding documents are properly filed in the local countries
• Put in place the requirements listed out in Tigers Tax Code of Conduct and seek clarification from the Group whenever necessary

Group reviewers should:

• Undertake subsidiary company tax provision reviews following reporting instructions guidelines;
• Undertake a review and update of group level transfer pricing provisions.
• Prepare, subject to all inputs, the group’s consolidated tax charge in accordance with all applicable governance and accounting requirements • Ensure appropriate briefing of the Board of Directors
• Liaise with/brief counterparts in Geopost.