UK Tax Strategy
Roche Products Limited (“RPL”), Roche Diagnostics Ltd (“RDL”) and Roche Diabetes Care (“RDC”) are limited liability companies registered in England and Wales and are wholly owned subsidiaries of the Roche Group resident in Switzerland.
The Roche Group’s strategy is to focus on finding new medicines and diagnostics that help patients live longer better lives and evolve the practice of medicine.
- RPL is involved in the sale of branded prescription medicines in the UK as well as participating in the global development programmes of the Roche Group in the field of prescription medicines.
- RDL imports, markets, distributes and services diagnostics equipment including diagnostic reagents to the UK and Irish healthcare markets and as well as supplying authorised distributors in Israel, Cyprus, Malta and Iceland with diagnostics products.
- RDC imports, markets, distributes and services diabetes care equipment and associated consumables to the UK and Irish healthcare markets
Our business activities incur a substantial amount and variety of business taxes including corporate income taxes, employment and other taxes. In addition, we collect and pay employee taxes and indirect taxes such as Value Added Tax (VAT). We operate policies and governance to ensure compliance with UK tax law.
In accordance with the companies’ and the Roche Group’s continued commitment to transparency, and UK legal requirements, this document sets out:
- Our approach to governance, risk management and compliance with UK tax laws
- Our approach to tax planning as affecting UK taxation
- The level of UK tax risk we are prepared to accept
- Our approach towards dealings with the HMRC
Governance, risk management and compliance with UK tax laws
We are committed to compliance with all statutory obligations and full disclosure to the HMRC. Tax compliance for us means paying the right amount of tax at the right time. It involves disclosing all relevant facts and circumstances to HMRC and claiming reliefs and incentives where available and in accordance with applicable legislation.
Governance for the correct application of and compliance with UK tax law is a responsibility of Board of Directors of each company and the specific responsibility of the respective Finance and Corporate Services Directors.
We 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 requirements of preparing the legal requirement to file a Senior Accounting Officer certificate.
Our approach to tax planning as affecting UK taxation
The companies plan their taxes with reference to current relevant legislation. When entering into commercial transactions, we seek to take advantage of available tax incentives, reliefs and exemptions, where appropriate, in line with UK tax legislation – for example R&D tax credits.
We do not undertake tax planning unrelated to commercial transactions.
Reliance is placed upon external tax advisors where there is need for specialist guidance and support, for example benchmarking analysis to support transfer pricing arrangements.
We apply the OECD transfer pricing guidelines to intercompany transactions.
The level of UK tax risk we are prepared to accept
The level of UK tax risk we accept is consistent with the companies’ and Group’s broader business risk management, compliance and transparency framework. We adopt the Group’s 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.
There are no pre-defined limits as to the amount for acceptable tax risk; it is judged on an issue by issue basis. Where the applicable laws and regulations are subject to interpretation, we seek appropriate assurance regarding the position taken; through the use of professional advisors and where appropriate direct from HRMC.
Our approach towards dealings with the HMRC
We are committed in maintaining a transparent and open relationship with HRMC.
As such, we ensure that HMRC, through their appointed Customer Relationship Manager (CRM) is kept aware of significant transactions and changes in the business and the companies seek to discuss any related tax issues as soon as possible.
Any inadvertent errors in submissions made to HMRC are fully disclosed and corrected as soon as is reasonably practicable.
Where HMRC takes a different interpretation of the tax impact of a particular business transaction, we seek to resolve this issue though open dialogue in a prompt and responsible manner.
HMRC performs periodic risk reviews of the companies and the most recent rating is “low risk”. We are committed to working with HMRC to ensure that this low risk status is maintained in the medium and long term.
Date of preparation: October 2018