Global Tax Policy

Ashurst is a leading international law firm operating in 21 countries. We are required by law to set out certain elements of our tax strategy and we do this below in accordance with the specific requirements applicable to the countries we operate in¹ . This policy applies for financial year ending 30 April 2024 and all subsequent years until superseded

1. Compliance

We are committed to complying with the relevant tax law and practice. We recognise the importance of ensuring the business pays the right and proper amount of tax and understand that collecting and paying tax is an important contribution to the government authorities in the countries we operate. This means paying the right amount of tax in the right place at the right time and making returns accurately and on a timely basis. It involves disclosing all relevant facts and circumstances to the relevant tax authorities whilst claiming reliefs and incentives that are available. It also means notifying staff and implementing procedures to ensure compliance with more recent obligations. We expect all our partners to comply with applicable tax laws.

2. Governance

Tax matters routinely affecting the business are handled internally by a dedicated team of experienced and qualified professionals who report to the Chief Finance Officer (the "Internal Tax Team"). The Audit and Finance Committee has oversight of the Internal Tax Team and regularly monitors compliance. On any significant tax matter affecting the firm, the Internal Tax Team will consult with and obtain approval from the Chief Finance Officer, the head of the Internal Tax Team and one or more tax partners from within the firm. That tax group is responsible for formulating the tax policy for the firm. It reports to the Board of Ashurst, via the Audit and Finance Committee (refer to our Tax Risk Management Policy).

3. Risk Management

To ensure consistency and compliance with tax legislation, tax risk is managed within Ashurst by operating to a set of documented policies, procedures and governance structures which describe the strategy and operational aspects of tax and set the framework for how and by whom it is managed. We aim to ensure that all individuals within Ashurst with tax responsibilities or whose business activity may have a tax impact, have a consistent and updated understanding of how tax risk is identified, assessed, reported and managed. We provide training and have published a global anti-tax evasion policy to ensure all employees understand the firm's zero tolerance approach to facilitation of tax evasion. Where appropriate, we engage external professional advisers to review tax legislation and its applicability to our business.

4. Tax Planning

In structuring and operating our business we will take into account the tax laws of the jurisdictions in which we operate. Tax will be considered as part of any major decision affecting our business and our structure so that our tax strategy is aligned with our business and commercial strategy. We do not enter into artificial arrangements (those without business or commercial substance) to avoid taxation or to achieve a tax advantage. We will utilise any applicable tax incentives and opportunities for obtaining tax efficiencies only where these:

• do not carry reputational risk or jeopardise our low risk rating with tax authorities;
• are aligned with the intended policy objectives of the respective governments which introduced them; and
• are aligned with our business or operational objectives.

5. Dealings with tax authorities²

Our policy towards tax authorities centres on the making of full and honest disclosures on a timely basis so as to develop a strong relationship based on transparency and trust. Regular meetings are held with the relevant tax authorities where we explain our business and discuss material tax matters where there is uncertainty as to how tax legislation or practice impacts our business. We seek to resolve differences through open discussion.

Last updated on 30 April 2024.

^1. Finance Act 2016 Schedule 19 Part 2 in the UK.

^2. For UK tax purposes the reference to tax authorities should be read as HM Revenue & Customs ('HMRC')