1. Introduction

Weybourne Limited is the head of the UK sub-group of Weybourne Holdings Pte Ltd (“the UK Group”) and this document deals with the UK Group’s obligations under Paragraph 16(2) of Schedule 19 of the Finance Act 2016 to publish a UK tax strategy in respect of the period ended 31 December 2022.

By way of background, Weybourne Holdings Pte Ltd and its subsidiaries (the “Group”) operate across the world.  The Group is headquartered in Singapore.  Its main operation is Dyson Holdings Pte Ltd and its subsidiaries (the “Dyson Group”) whose principal activity is the development of new technology and the manufacture and sale of products incorporating that technology.  The Group also includes Dyson Farming Ltd, which owns and farms land in the UK.  In addition, Weybourne Holdings Pte Ltd operates an ancillary financial investment and commercial property business.  The Group is subject to tax across a number of countries and under different tax regimes, including the UK.

The Group also has a formal Tax Policy which provides a comprehensive framework to manage tax risks and to ensure that The Group is protected from any financial, reputational, operational or regulatory risk.  It is designed to help all employees understand the tax risks involved and how best to protect Weybourne from them.

The Group has a zero tolerance towards tax evasion and the criminal facilitation of tax evasion. In addition, the Group ensures compliance with all tax regulatory requirements.

2. Tax planning strategy

The Group has a documented code of conduct, to which the UK Group must comply. Amongst the principles enshrined in it are compliance with the law and with moral obligations.  All staff are required to follow these principles, including in all dealings in relation to UK tax.   The Group ensures that all its UK tax obligations are met as required and seeks to ensure that UK tax is paid where and when it is due.

The UK Group interprets UK tax laws in the way it believes they were intended to apply and does not seek to use UK tax laws in a contrived manner.

In cross-border matters, the Group follows the terms of double tax treaties and relevant OECD guidelines in dealing with matters such as transfer pricing and establishing taxable presence.

3. Relationships with tax authorities

The UK Group works collaboratively with the UK tax authorities to achieve certainty on a real-time basis, and to achieve early agreement, where possible.

Where the amount of UK tax due is subject to a significant degree of uncertainty, the UK Group actively engages with the UK tax authorities and seeks binding rulings as to the level of profits taxable.  By working with the UK tax authorities, where possible in real-time through an open relationship, the UK Group increases certainty over its tax affairs.

Due to the complexity of UK tax legislation, the UK Group and the UK tax authorities may occasionally have differing opinions on the treatment of certain tax items.  Where this is the case, the UK Group works with the UK tax authorities to reach resolution as promptly as possible.

4. Tax risk management

The UK Group’s risk management (which includes tax risks) is overseen by the Board, supported by the UK Group’s Audit Committee, to which the Internal Audit functions report.

The UK Group maintains an up-to-date register of tax risks.  All material tax risks are discussed with the Internal Audit function to ensure adequate controls and processes are in place to monitor and report against such risks.

The two key tax risks, and details of how the UK Group manages them are:

1. a) Complexity and changes in legislation – The UK Group is subject to tax in the UK. UK tax legislation is complex and is typically updated on an annual basis. To keep up with these changes, the UK Group ensures that its tax functions have access to tax updates, access to specialist training and opportunities to obtain professional tax qualifications.  The UK Group also utilises the services of external tax advisors as and when required.
2. b) Compliance and reporting risk – The UK Group is required to meet many different UK tax compliance and reporting obligations. If these are not complied with, the UK Group could suffer penalties and interest.  The UK Group uses a combination of timetables and checklists to ensure that all compliance and reporting obligations are met in accordance with statutory deadlines.

Additionally, the risk register is reviewed and reported against as part of the UK’s annual Senior Accounting Officer certification process.

5. Governance

The Group’s Chief Financial Officer (CFO) is responsible for the implementation of the UK Group’s approach to tax.    As part of the annual financial reporting process, the CFO communicates relevant information on the UK Group’s tax position to the Board of Directors.

The responsibility for the day-to-day management of the UK Group’s tax operations is devolved to the internal tax functions, which are staffed by appropriately qualified and trained employees.  External tax support is sought on occasions when specialist expertise is required or when the Group wishes to seek advice on the UK tax position of a particular matter.

6. Further information

This UK Tax Strategy reflects the Group’s approach to tax.  The UK tax strategy is reviewed and updated annually.

This document complies with the UK Group’s obligations under Paragraph 16(2) of Schedule 19 of the Finance Act 2016 to publish a tax strategy in respect of the period ended 31 December 2022.

Approved by: Sir James Bucknall, Director

Date: December 2022

On behalf of Weybourne Limited