UK Tax Strategy

For the financial year ended 31 December 2023. The publication of this strategy statement is regarded as satisfying the statutory obligation under paragraphs 19(2) and 22(2), Schedule 19, Finance Act 2016 for the UK companies within the Roche Group.


This paper has been prepared and published to comply with Paragraph 19 (2) Schedule 19 Finance Act 2016 (‘UK sub-groups: Duty to publish a group tax strategy’) and Paragraph 22(2) (‘Qualifying companies: Duty to publish a company tax strategy’) for the year ended 31 December 2023.

The tax strategy described herein has been prepared for all UK entities with the worldwide group of Roche Holding AG (‘Roche’). Entities covered by this strategy paper are Roche Holding (UK) Ltd, Roche Products Ltd, Roche Diagnostics Ltd, Roche Diabetes Care Ltd, Roche Products Pension Trust Ltd, Roche Healthcare Trustees Ltd, AVL Medical Instruments UK Ltd, Ventana Medical Systems Ltd, Spark Therapeutics UK Ltd, Flatiron Health UK Ltd, TMEM16A Ltd, Intermune Holding Ltd, Roche Registration Ltd, Piramed Ltd, Tusk Therapeutics Ltd, and Inflazome UK Ltd. They are collectively referred to as ‘Roche UK’ within this paper.  Chugai Pharma Europe Ltd and Chugai Pharma UK Ltd publish their own tax strategy. This paper is reviewed annually, and updated as appropriate and approved by the Board of Directors.

Roche’s strategy is to focus on finding new medicines and diagnostics and establishing data-based insights that evolve the practice of medicine and help patients live longer, better lives. Roche strive to address unmet medical needs through excellence in science – from early detection and prevention of diseases to diagnosis, treatment and treatment monitoring.

Roche UK business activities incur a substantial amount and variety of business taxes including corporate income taxes, Pay As You Earn, National Insurance Contributions and other taxes. In addition, Roche UK collect and pay employee taxes and indirect taxes such as VAT. Roche UK operates policies and governance to ensure compliance with UK tax law.

Roche UK’s approach to tax

Roche UK operates policies and governance to ensure compliance with UK tax law and it follows the Roche group approach to tax. In complying with UK tax law, Roche UK considers the spirit in which the UK tax law is intended.

Transfer Pricing

One of the basic principles for sustainable tax management is that taxes should be paid where economic value is generated. Roche applies the “OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations”, first issued in 1995. In order to prevent or at least reduce the probability of double taxation, Roche applies the OECD transfer pricing guidelines as an overarching principle.

Transfer prices take into account functions performed, assets used, and risks assumed as well as documentation of the arm’s length nature of the prices. Transfer pricing decisions are taken in a balanced manner considering the basic principle for sustainable tax management that taxes should be paid where economic value is generated.


As a minimum standard the OECD/G20 requires countries to request multinational enterprises to prepare and file a Country-by-Country report containing aggregate tax information per country. For Roche UK this report is filed with the Swiss Tax Administration.

Approach to risk management and governance arrangement in relation to UK taxation

Roche UK are committed to compliance with all statutory obligations and full disclosure to HM Revenue & Customs. Tax compliance for Roche UK means paying the right amount of tax at the right time. It involves disclosing all relevant facts and circumstances to HM Revenue & Customs and claiming reliefs and incentives where available and in accordance with applicable law.

Governance for the correct application of and compliance with UK tax law is a responsibility of the Board of Directors of each UK company and the specific responsibility of the respective Finance Directors.  They are assisted by the Head of Tax UK &I who manages an in-house team of appropriately qualified and experienced tax professionals who undertake the day to day activities. The UK tax team ensure that their tax knowledge is up to date through appropriate training on an ongoing basis and by monitoring and keeping up to date with changes in tax law.

Roche UK have established and maintain robust policies and processes to ensure that taxes are calculated correctly, paid in a timely manner and risk of error is minimised. 

Tax policies and procedures are continually monitored and updated and employees involved are provided with appropriate training and professional support.  An annual review of tax processes and procedures is undertaken to comply with the legal requirement to file a Senior Accounting Officer certificate.

Attitude towards tax planning so far as it affects UK taxation

Roche UK plans its taxes with reference to the relevant UK tax law. When entering into commercial transactions, Roche UK seeks to take advantage of available tax incentives, reliefs and exemptions, where appropriate, in line with the UK tax law (e.g. research & development expenditure credits). If there is an element of uncertainty over the application or interpretation and application of the tax law Roche UK will seek external advice from a reputable professional adviser for clarity of the position.

Roche UK do not undertake any tax planning unrelated to commercial transactions. No artificial or aggressive tax planning arrangements are entered into.

Roche UK undertakes its intercompany transactions on an arms length basis in compliance with the relevant tax law and OECD transfer pricing guidelines.

The acceptable level of risk accepted in relation to UK taxation

The level of UK tax risk Roche UK accepts is consistent with the Roche’s broader business risk management, compliance and transparency framework.  Roche UK adopts Roche’s group risk management training for all employees covering all relevant aspects of good and compliant business practice.

In relation to any specific issue or transaction, the Boards of Directors are ultimately responsible for identifying the risks, including tax risks, which need to be addressed and for determining what actions should be taken to manage those risks, having regard to the materiality of the amounts and obligations in question.

In some cases Roche UK and HM & Revenue & Customs may disagree on the correct application of the law and in these circumstances tax risk is judged on a case by case basis but consideration is given to the financial and reputational impact, complexity and how likely the risk is to arise. Roche UK generally takes a very conservative approach towards tax risk.

Approach towards dealings with the HM Revenue & Customs

Roche UK are committed to maintaining a transparent and open relationship with HM Revenue & Customs. The Head of Tax UK &I has regular dialogues with the appointed Customer Compliance Manager, who is kept aware of significant transactions and changes in the business. Where tax issues arise Roche UK seeks to discuss them as soon as possible with HM Revenue & Customs and agree a way forward.

Any inadvertent errors in submissions made to HM Revenue & Customs are fully disclosed and corrected as soon as is reasonably practicable. 

Where HM Revenue & Customs takes a different interpretation of the tax impact of a particular business transaction to Roche UK and its external advisers, Roche UK seeks to resolve the issue though open dialogue in a prompt and responsible manner.

The tax strategy described herein has been formally adopted by the Board of Directors of Roche Holding (UK) Limited and has been approved by Roche Group Tax.

Updated December 2023

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