Siemens UK Tax Strategy - Year ending 30 September 2022
This page sets out the strategic tax objectives for Siemens UK as required by Finance Act 2016, Sch 19 paras 19 and 22.
This strategy applies to all Siemens UK entities, including Siemens Healthcare entities, as well as overseas group companies with a taxable presence in the UK and in this strategy references to ‘Siemens UK’ are to all these companies. For confirmation – it does not apply to the Siemens Energy group which is a separate organisation.
The Chief Financial Officers of the relevant companies and Head of Tax are responsible for management of the tax affairs of the group. Our tax strategy is reviewed annually. The latest review took place in October 2021 and the next review will take place in October 2022 unless circumstances warrant earlier action to be taken.
The tax strategy is approved by the managing board of Siemens UK and sets out the group's general tax arrangements as well as the policy and approach to tax risk management, attitude to tax planning and working with HMRC.
The processes and controls which support the delivery of the strategic tax objectives are regularly reviewed.
References to ‘UK taxation’ are to the taxes and duties in the UK which include:
- All corporate income taxes
- Indirect taxes (VAT, Stamp Duty Land Tax)
- Employment taxes (PAYE / National Insurance)
- Construction Industry Scheme and other applicable tax matters
Aim and Alignment with group policy
As part of a multinational group we are aligned with and follow the wider Siemens guiding principles, code of conduct and tax policy for the group.
Siemens premise is that ‘Only clean business is Siemens business’ and that this is done always with the highest level of integrity.
The organisation operates a set of Business Conduct Guidelines which lay out rules which all businesses and employees must act in accordance with. The guidelines must also be applied by all companies and associated persons working with Siemens.
These include the requirement that observing the law and the legal system (as well as all applicable Siemens policies) is a fundamental principle for Siemens. Violations of the law must be avoided under all circumstances and a zero tolerance approach is applied.
The guiding principles for the tax organization are:
We act as a responsible global corporate tax citizen in compliance with applicable tax law and regulations.
We encourage ethical and transparent business practices and do not employ legal entities for purposes of tax avoidance.
We encourage an open and honest dialogue between tax policy makers and business.
We actively engage in the development of a rule based international tax framework.
We make tax part of every important business decision.
We report and disclose our tax positions in accordance with applicable regulations and requirements.
Tax code of conduct and tax policy at Siemens
We see the strict compliance with the legal framework set by national legislators and internationally recognised standards as our obligation.
The increasing complexity and uncertainty in the international and national tax systems requires us to have mechanisms in place that ensure all policies and regulations are adhered to. It is our primary objective to act in accordance with the respective tax laws in the countries we operate in.
Siemens in the UK
As of October 2021, Siemens global business is structured into 3 focused and operationally independent companies – Siemens, Siemens Energy and Siemens Healthcare. The Siemens core activities include those of Digital Industries, Mobility and Smart Infrastructure.
Siemens Energy is a non-consolidated company and is separately managed. It is not covered by this Tax Strategy.
Tax strategy and strategic objectives
The tax strategy and strategic objectives are intended to establish a clear and unequivocal approach to all aspects of tax reporting and compliance for all industries the company operates in. This supports robust internal governance which defines our control framework.
The tax strategy is focused on ensuring that taxes (and tax risks) are managed to provide outcomes consistent with commercial reality and are within the parameters of the Group’s strategic objectives. The strategy also requires that all tax obligations are complied with in the UK and other relevant jurisdictions.
With the tax landscape constantly changing, Siemens UK’s tax affairs and tax risk management procedures are regularly reviewed to ensure that processes and measures are up-to-date so that we are able to identify, assess, manage and mitigate tax risk as well as being aligned with the Siemens Group’s business strategy and governance framework.
Siemens UK must comply with all tax filing and disclosure requirements and pay the right amount of tax in respect of its operations.
Tax risk management and risk
Siemens UK only structures its affairs based on sound commercial principles and in accordance with the Siemens Group policy and relevant tax legislation.
Siemens UK does not engage in artificial tax arrangements and ensures that the outcomes are consistent with commercial realities.
Siemens UK utilises tax reliefs and allowances available in the manner in which intended by relevant tax authorities, statute and legal precedent. There will, however, be circumstances where this amount may not be clearly defined, or where alternative approaches may result in differing tax outcomes. The Group will use its best judgment in determining the appropriate course of action, obtaining external advice and liaising with tax authorities (including HMRC) where appropriate.
Siemens seeks to reduce the level of tax risk arising from its operations, its business partners and any other associated persons as far as is practically reasonable by following internal guidelines and using relevant tools.
Identification of key risks and the operation of mitigation processes are undertaken by appropriate specialist functions within the tax team. These key risks are monitored for changes in business, legislation and OECD driven policy initiatives and are updated accordingly.
The day-to-day management of Siemens UK tax affairs is provided by the UK tax team. The tax team have appropriate qualifications and relevant experience and are supported by advisors where required considering the complex and changing tax environment.
Relationship with HRMC
It is Siemens UK’s policy to be transparent and proactive in all interactions with HMRC through regular meetings and communications with HMRC.
We have an open, honest and positive working relationship with HMRC. We are committed to prompt disclosure and transparency in all tax matters with HMRC. We recognize that there will be areas of differing legal interpretations between ourselves and HMRC and where this occurs we will engage in proactive discussion to bring matters to a timely and appropriate conclusion.
Any inadvertent errors in submission of tax returns and tax computations to HMRC are fully disclosed as soon as reasonably practicable after they have been identified.