United Kingdom

UK Tax Strategy

INTRODUCTION

This document sets out the :

  • the UK tax strategy of the UK legal entities of Guerbet’s Group; and 
  • approach to conducting their tax affairs and dealing with tax risks in the UK

for the year ending 31 December 2018. 


UK CONTEXT

Schedule 19 of 2016 Finance Act requires that certain companies, including Guerbet Laboratories UK Ltd., publish annually a statement of their Tax Strategy.

The following legal entities, each part of the Guerbet UK group, are subject to taxation in the UK and covered by this Statement:

  • Guerbet Laboratories UK Ltd.
  • Guerbet Imaging UK Ltd.
  • Guerbet Argentina Ltd.


GUERBET LABORATORIES UK LIMITED
 

As a Guerbet UK Legal Entity part of Guerbet’s Group, Guerbet Laboratories UK Limited is committed like the other UK entities of the Group to conducting its tax affairs in accordance with the following objectives:

COMMITMENT TO TAX COMPLIANCE

Tax is managed by an integrated team of specialists (tax specialists, accountants and UK local financial controller) reporting to their managers (respectively Head of Tax, Accounting Director and UK General Manager) and globally to the Global Chief Financial Officer. They deal with Tax Compliance, Tax Accounting & Reporting, Indirect Tax, Corporate Tax Audit, and Transfer Pricing. To perform their Tax duties, they utilize professionals from international accounting firms to assist with identifying and resolving UK tax issues resulting from legislative or business changes, and for the preparation of Corporate tax filings in the UK. Both UK Local Financial Controller and Tax Department consult regularly with such outside professionals and ensure that the necessary facts and circumstances have been communicated to those third parties to allow for the proper resolution of issues and correct completion of returns. All tax returns are reviewed and approved by UK Local Financial Controller prior to filing.

Guerbet Laboratories UK Limited will make every effort to comply with all laws, regulations, rulings, and information reporting requirements on a timely basis in all jurisdictions where it operates, including the UK. This includes remittance of the correct amount of tax on a timely basis and disclosure of all relevant information to the tax authorities. Guerbet Laboratories UK Limited will utilize tax incentives and reliefs to minimize the tax costs of its business but will not knowingly use such incentives and reliefs in a manner which contradicts the intent of the provisions.

ATTITUDE CONCERNING TAX PLANNING

Guerbet’s Group has adopted a Code of Conduct and other internal policies and guidelines intended to support its mission statement and to comply with the laws, rules and regulations that govern its business operations. The Code applies to all directors, officers and employees of Guerbet.


In structuring its commercial activities, it will consider – among other factors – the tax laws of the countries within which it operates with a view to maximizing value on a sustainable basis for Guerbet shareholders. Any tax planning undertaken will have commercial and economic substance and will consider the potential impact on Guerbet’s reputation and broader goals. It will not undertake planning that is contrived or artificial. 


ACCEPTED LEVEL OF TAX RISKS

Given the scale of the business and the volume of tax obligations, on occasion risks will inevitably arise in relation to the interpretation of the tax law. It will ensure that the selected tax strategy is aligned with the Guerbet overall strategy and approach to risk management, is consistent with the Guerbet Vision, Mission, and Values statement, and is approved by the appropriate level of management.

APPROACH TO DEALING WITH TAXING AUTHORITIES INCLUDING HMRC 

Guerbet Laboratories UK Limited seeks to foster positive and professional relationships with tax authorities based on integrity and collaboration.


They committed to the principles of openness and transparency in their approach to dealing with HMRC, and in particular commit to:

  • Adopt open and collaborative professional relationships at all times with HMRC ;
  • Engage in full, open and early dialogue with HMRC to discuss tax planning, strategy, risks and significant transactions ;
  • Make fair, accurate and timely disclosure in correspondence and respond to queries and information requests in a timely fashion ;
  • Seek to resolve issues with HMRC in real time and where disagreements arise work with HMRC to resolve issues by agreement where possible ;
  • Be open and transparent about decision-making, governance and tax planning ;
  • Reasonably believe that transactions are structured to give a tax result which is not inconsistent with the economic consequences (unless specific legislation anticipates that result) ;
  • Interpret the relevant laws in a reasonable way, and ensure transactions are structured consistently with a co-operative relationship.

RISK MANAGEMENT AND GOVERNANCE 

The strategy is aligned with the Guerbet Vision, Mission, and Values statement, and is approved and overseen by the Board.

The Tax risk is managed in the UK by :

  • ensuring that there are appropriately qualified and experienced employees in the Finance function (tax specialists, accountants and local financial controller);
  • using external advisors for consulting and compliance assistance, review and tax law updates.

Changes in Tax legislation

The Group actively monitors new tax legislation and any changes of interpretation of existing legislation applicable in the UK with the assistance of external tax advisers providing UK and International Tax Law Updates by means of regular calls, newsletters, memos. 

It seeks external assistance from professional advisors and clarification from HMRC where necessary and appropriate.