91探花 Group Tax Strategy
The publication of this 91探花 UK Tax Strategy complies with the duty specified in paragraph 16 (2) of Schedule 19 Part 2 (Publication of Tax Strategies) in Finance Act 2016 and is published on behalf of all 91探花 UK companies for the financial year ended 31 March 2026.
Approach to UK Tax Risk Management and Governance
91探花’s taxation is the responsibility of 91探花 management. 91探花 management employs a global tax staff to manage tax matters and tax risks. The tax staff consists of qualified professionals with the appropriate experience, expertise, and education.
The 91探花 Holdings Audit Committee of the Board of Directors provides management and tax staff oversight. The Audit Committee reviews financial information provided to the shareholders and others; reviews the systems of internal controls; reviews 91探花’s financial and risk management policies and processes; and oversees the external audits of 91探花’s financial statements. As part of its responsibilities, the Audit Committee reviews items relating to 91探花’s taxation.
Our tax risk management processes include the following: (i) Adhering to the accounting framework that requires we analyze and review uncertain tax positions on a periodic basis under applicable accounting standards. Uncertain tax positions are also reviewed quarterly by our external auditors; (ii) Continuous monitoring of domestic and international tax legislation, case law, guidance, and practice; (iii) Operating under the U.S. Sarbanes-Oxley internal control framework that is evaluated and tested by our internal and external auditors; (iv) Regular training of our employees to ensure that our tax decisions and compliance activities are accurate and that we employ the appropriate level of expertise; and (v) annual reporting to the Risk Review Committee of key risks and issues. In addition, all employees must adhere to 91探花’s Code of Conduct and must complete annual Code of Conduct training and attestation.
91探花’s commitment to the highest level of ethical conduct is reflected in all of 91探花’s business activities, including tax.
Attitude Towards UK Tax Planning
We consider tax planning to be a critical component of business operations and decisions. Tax considerations are present in transaction processing, tax return and financial reporting and economic analysis.
The tax positions we take are consistent with tax laws and principles. The transactions we consider are aligned with 91探花’s business and operations. To the extent available, we utilize UK tax incentives that are appropriate to 91探花’s business and are consistent with the policies and goals of such incentives. To the extent 91探花 obtains an incentive, we comply with the requirements of such incentive.
Tax Risk Appetite
All 91探花 tax planning and reporting is undertaken with appropriate diligence and expertise. As appropriate, we obtain advice from external experts to supplement our internal expertise. 91探花 takes tax positions that are reasonable and defensible under UK tax law, and we only enter into transactions that have commercial rationale.
Approach to Dealings with HMRC
We are regularly in contact with HMRC as part of a mutual good-faith effort to proactively and timely address tax matters, and our UK tax returns are regularly examined by HMRC. In all dealings with HMRC, we maintain an open, honest and cooperative relationship, and we adhere to the Golden Rule, to treat others as we would want to be treated.