This document, approved by the board of STERIS plc, sets out the Group's approach to conducting its tax affairs and dealing with tax risks.
The STERIS plc group (the "Group") is committed to the following underlying tax principles:
Managing the Group's tax affairs is a complicated process across many separate and autonomous businesses and across multiple jurisdictions over five continents. As such there will inevitably be risks associated with ensuring the appropriate taxes are calculated, collected and settled in a timely manner in accordance with each one of the areas in which the Group operates. Although it is not possible to entirely eliminate tax risks, the Group's attitude towards the level of control required over tax processes is designed to reduce these tax risks and be proportionate to the perceived likelihood of occurrence and scale of impact of each risk.
Identified tax risks are assessed on a case-by-case basis to ensure each individual risk is managed appropriately. Where there is uncertainty in respect of a specific risk, the Group will consider whether to seek external advice to support the Group's evaluation of the risk or discuss with the relevant tax authority.
When considering a specific tax risk, the Group considers the following:
The Group has defined lines of responsibility for its tax affairs, with decisions being taken in line with the Group's tax authority thresholds, ensuring that they are taken at an appropriate level.
The Group's tax planning aims to support the commercial needs of the business by ensuring that the companies' affairs are carried out in the most tax efficient manner while remaining compliant with all relevant laws. The tax function is therefore involved in the commercial decision-making processes and provides appropriate input into business proposals to ensure a clear understanding of the tax consequences of decisions made.
In cases where the tax guidance is unclear or the Group feels it does not have the necessary expert knowledge to assess the tax consequences adequately, external advice generally will be sought from the tax authorities or advisors to support the Group's decision-making process.
Approach towards dealings with HM Revenue & Customs ("HMRC")
The Group is committed to the principles of openness in its approach to dealing with HMRC, and the Group endeavors to: