Updated December 2017

Introduction

The different UK divisions of the HORIBA Ltd group are headed up by HORIBA Mira Limited, HORIBA UK Limited, HORIBA Jobin Yvon IBH Limited, HORIBA UK Finance Limited and HORIBA Test Automation Limited.

Their policy is to comply with the tax laws and related regulations of all countries and regions in which they operate. The companies also adhere to tax guidelines announced by OECD and other international institutions.

In order to maximize corporate value, the UK companies aim to reduce their tax exposure by making use of reliefs available, as endorsed by each jurisdiction’s tax authority, and take steps to avoid double taxation. At the same time, the UK companies maintain compliance with tax requirements, obligations and policies.

This strategy has been approved by the respective Boards of Directors of each UK Company and is subject to regular review in order to keep up-to-date with changes to legislative rules and regulations.

Tax Risk Management

The tax strategy is set in consultation with the Finance Directors and Financial Controllers of the UK companies and is reviewed by the Board of Directors who are responsible for setting and monitoring the strategy.

The UK companies manage their tax risks by implementing the HORIBA group’s internal control system, actively maintaining a tax register and keeping up-to-date with changes in legislation. HORIBA’s policy and systems concerning corporate governance are published in the Securities Report and HORIBA Report, which are disclosed on the group’s corporate website.

To reduce tax-related risks, the UK companies take the following specific measures:

  • The finance teams provide accurate, timely and relevant tax advice to other teams within the UK companies.
  • External auditors perform statutory audits of the companies’ financial statements and assure the credibility of the financial information by providing an opinion on the companies’ compliance with accounting standards and guidelines.
  • The finance teams monitor the appropriateness of intercompany prices by ensuring transactions between connected parties comply with UK transfer pricing rules.
  • The finance teams seek professional advice from external tax experts and consultant firms when there is uncertainty around the tax treatment of specific items. They also seek advice in relation to any other matters that may arise when the companies are considering undertaking projects outside their normal business activities.
  • The companies communicate in a timely manner with H M Revenue and Customs (HMRC) where the tax treatment of items is uncertain.

Acceptable Tax Risks

Acceptable tax risks are limited to those that can be controlled by the aforementioned HORIBA corporate governance system, given consideration to the credibility and reputation extended by various stakeholders. There are no set levels of acceptable risk and everything is considered on a case by case basis when significant events or transactions occur in the business. The stakeholders involved then consider the tax risks as appropriate, based on their experience, reaching out to advisors or tax authorities when relevant.

Attitude To Tax Planning

The UK companies comply with UK tax laws and HMRC regulations and only engage in tax planning that is aligned with their substantive commercial business activity. The companies also aim to carry out their affairs in the most tax-efficient manner.

The companies apply the arm’s length principle to transactions between connected parties and do not enter into any arrangements whose main purpose is the avoidance of tax.

Approach To Working With Tax Authorities

The UK companies seek to develop a constructive and transparent relationship with HMRC. The companies make full disclosure to HMRC in all computations and returns, which are filed in a timely manner.

The UK companies work proactively with HMRC on tax matters, such as R&D tax relief claims, despite not having a Customer Relationship Manager.