UK TAX STRATEGY

Clyde & Co LLP regards this strategy statement as complying with its duty under Schedule 19 to the Finance Act 2016. This statement applies to Clyde & Co LLP and all UK affiliated entities for the financial year ended 30 April 2020 and subsequent financial periods until it is superseded.

The statement covers our approach to conducting our UK tax affairs and dealing with UK tax uncertainties and risk. It has also been approved by the Management Board of Clyde & Co who have responsibility for monitoring its application.

COMMITMENT TO COMPLIANCE

Clyde & Co is committed to full compliance with all statutory obligations and full disclosure to tax authorities in all of the territories in which it operates. That means paying the right amount of tax in the right place at the right time. It involves disclosing all relevant facts and circumstances to the tax authorities while claiming reliefs and incentives where available.

TAX PLANNING

When considering the firm’s global operations, tax is one of the factors we examine. The firm’s operational structure throughout the world is determined by regulatory restrictions but we do consider the impact of any applicable tax laws, both to ensure compliance and claim any reliefs that are intended to be available. We operate within the applicable tax framework and expect to pay tax in accordance with the local rules and in line with the substance of our activities. The level of tax paid is determined by the rates determined by local government.

We maintain or employ sufficient resources to monitor our tax position and to ensure we meet our reporting, filing and payment obligations in an accurate and timely basis.

RISK MANAGEMENT

Given the scale of our business and the volume of our tax obligations, tax uncertainties and risks will inevitably arise from time to time with respect to the interpretation of tax laws and the nature of our compliance obligations. We proactively seek to identify, evaluate, manage and monitor tax uncertainties and risks to ensure they are appropriately addressed in accordance with these principles. Responsibility and accountability for the firm's tax affairs is agreed and decisions will be taken at an appropriate level. Where there is significant uncertainty or complexity in relation to risk, we take appropriate professional advice and/or discuss the matter with the relevant tax authority.

DEALINGS WITH HMRC

We engage with HMRC openly and honestly and in a spirit of cooperative compliance. Where there are areas of tax law that are considered to be uncertain we are committed to seeking external professional advice to ensure full compliance with all statutory obligations.

Our business’s approach and tax strategy is communicated to HMRC and reflected through our pro-active and open interaction with our Customer Compliance Manager.

GOVERNANCE

Clyde & Co.’s Management Board is ultimately responsible for the firm’s internal risk management and controls, which includes this UK tax strategy and compliance. Day to day responsibility for the management of our UK tax affairs is delegated to our appropriately qualified Global Tax Team, who ultimately report to the Chief Finance Director, with oversight from our Risk Committee.

We provide our members with an internal tax withholding to ensure sufficient funds are available to meet their obligations as they relate to Clyde & Co matters.

At all times Clyde & Co 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.

This statement is made available to all our stakeholders and will be reviewed annually by the Management Board.

Published April 2020