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UK Tax Statement

1. Introduction

M3 (EU) Ltd, a limited company registered in England and Wales, is wholly owned by M3 Inc. This strategy applies to M3 (EU) Ltd referred to as “M3” in this strategy, in accordance with paragraph 19 of Schedule 19 to the Finance Act 2016. The strategy has been published in accordance with paragraph 19(4) of the Schedule.

 

This strategy applies from financial year 2020, until it is superseded. References to ‘UK Taxation’ are to the taxes and duties set out in paragraph 15(1) of the Schedule which include Income Tax, Corporation Tax, PAYE, NIC, VAT, Insurance Premium Tax, and Stamp Duty Land Tax. References to ‘tax’, ‘taxes’ or ‘taxation’ are to UK taxation and to all corresponding worldwide taxes and similar duties in respect of which the Group has legal responsibilities.

 

M3 Tax strategy is underpinned by key policies below to ensure that we are a responsible global corporate tax citizen.

2. Aim

M3 strives for full compliance with all statutory obligations, internationally recognised standards and full disclosure to relevant tax authorities. The group’s tax affairs are managed in a way which takes into account the group’s wider corporate reputation in line with M3’s overall high standards of governance, core ethical behaviours and values.

3. Governance in relation to taxation

  • Ultimate responsibility for M3’s tax strategy and governance rests with the M3 Inc Board
  • Responsibility for governance for all matters relating to taxation is delegated to the Finance Director at M3 (EU) Ltd.
  • The Board ensures that tax strategy is one of the factors considered in significant investments and business decisions taken.
  • The Finance Director reports to the Board on tax affairs and risks.
  • Local management of each legal entity is responsible for ensuring that all applicable regulations as well as internal guidelines and governance procedures relating to taxation are observed.
  • The Tax and regional teams are staffed with appropriately qualified individuals.

4. Risk Management

  • M3 operates a system of tax risk assessment and controls as a component of the overall internal control framework.
  • Processes relating to different taxes are reviewed regularly in order to identify key risks and implement mitigating internal controls. These key risks are monitored for business and legislative changes which may impact them and changes to processes or controls are made when required.
  • Potential tax risks are assessed and processes and controls are implemented to mitigate the risks to an acceptable low level.
  • Internal control procedures and processes are subject to regular reviews.
  • Advice is sought from external advisers where appropriate.

5. Attitude towards tax planning and level of risk

  • M3 manages risks to ensure compliance with legal requirements in a manner which ensures payment of the right amount of tax.
  • M3 does not engage in artificial tax arrangements, i.e. planning that is not underpinned by commercial and economic substance. Tax planning measures are always in line with the tax legislation with a low risk of non-acceptance by Tax Authorities. Advice is sought from external advisers where uncertainty exists.
  • When entering into commercial transactions, M3 seeks to utilise available tax incentives, reliefs and exemptions in line with and in the spirit of tax legislation.
  • At all times M3 seeks to comply fully with its regulatory and other obligations and to act in a way which upholds its reputation as a responsible corporate citizen.

6. Relationship with HMRC

  • M3 has a transparent, open and constructive relationship with HRMC. Through regular communication in respect of developments in M3’s business, current, future and retrospective tax risks, and interpretation of the law in relation to all relevant taxes.
  • M3 ensures that Tax Authorities are kept aware of significant transactions and changes in the business and seeks to discuss any tax issues arising at an early stage. When submitting tax computations and returns, M3 discloses all relevant facts and identifies any transactions or issues where it considers that there is potential for the tax treatment to be uncertain.
  • M3 makes the necessary corrections of material errors or misstatements in tax filings where permissible and/or required by law and practice without undue delay. Any inadvertent errors in submissions made to Tax Authorities are fully disclosed as soon as reasonably practicable after they are identified.