This strategy statement covers the UK operations of STERIS plc represented by STERIS Limited and its UK direct and indirect subsidiaries (the “UK Sub-group”) and is intended to satisfy the UK tax strategy publication requirement under paragraph 16(2) of Schedule 19 to Finance Act 2016.
The UK Sub-group is committed to the following underlying tax principles:
Managing the UK Sub-group's tax affairs is a complicated process across many separate and autonomous businesses and across multiple jurisdictions. 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 Sub-group operates. Although it is not possible to entirely eliminate tax risks, the UK Sub-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. The Audit Committee of the Board of Directors of STERIS plc is provided with annual updates with regard to tax issues including relevant worldwide tax developments, tax audits and tax controversy.
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 UK Sub-group will consider whether to seek external advice to support the UK Sub-group's evaluation of the risk or discuss with the relevant tax authority.
When considering a specific tax risk, the UK Sub-group considers the following:
The UK Sub-group has defined lines of responsibility for its tax affairs, with decisions being taken in line with the authority thresholds established by STERIS plc, ensuring that they are taken at an appropriate level.
The UK Sub-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 UK Sub-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 Sub-group's decision-making process.
The UK Sub-group is committed to the principles of openness in its approach to dealing with HMRC, and the UK Sub-group endeavours to: