About Shionogi

Shionogi Limited - Our tax strategy in the UK

Introduction

SHIONOGI Limited in UK is the European headquarters of Shionogi & Co. Ltd. of Japan, a global pharmaceutical company based on strong R&D capabilities and cutting-edge science. Our mission is that “Shionogi strives constantly to supply the best possible medicine to protect the health and wellbeing of the patients we serve”. We strive to be a world-class operator, a responsible corporate citizen and a good employer.

Our business activities in Europe are still in a growth phase and in time will generate a substantial amount and variety of taxes. We pay or will pay corporate income taxes and other taxes. In addition we collect and pay employee taxes as well as indirect taxes such as excise duties and VAT.

SHIONOGI is committed to complying with tax laws in a responsible manner and to having open and constructive relationships with tax authorities. SHIONOGI supports efforts to increase public trust in tax systems. We engage in initiatives to simplify and improve tax regimes to encourage investment and economic growth.

SHIONOGI’s code of conduct sets out what is expected of everyone at SHIONOGI and our approach to tax aligns with that.

Our commitment is underpinned by the following principles:

1. Governance and risk management

The group CFO and head of tax owns and implements our global approach to tax. The head of tax is also responsible for ensuring that policies and procedures that support the approach are in place, maintained and used consistently around the world, and that the global tax team has the skills and experience to implement the approach appropriately.

2. The level of risk in relation to UK taxation that we are prepared to accept

UK tax risk is managed as part of the global tax strategy of Shionogi Group, upon which the global tax team including Shionogi Limited meet and update on a periodic basis each year. We identify, assess and manage tax risks and account for them appropriately. We implement risk management measures including controls over compliance processes and monitor their effectiveness. We therefore have a low tax risk tolerance in the UK.

We report on a periodic basis to the company’s board on how compliance risks are managed, monitored and assured and on improvements that are being made. In this way the company’s board provides governance and oversight of tax risks.

3. Our attitude towards tax planning

We engage in efficient tax planning that supports our business and reflects commercial and economic activity. We do not engage in artificial tax arrangements.

We adhere to relevant tax law and we seek to minimize the risk of uncertainty or disputes.

We conduct transactions between SHIONOGI group companies on an arm’s-length basis and in accordance with current OECD principles, supported by suitable transfer pricing analysis and documentation.

Tax incentives and exemptions are sometimes implemented by governments and fiscal authorities in order to support investment, employment and economic development.

Where they exist we seek to apply them in the manner intended.

We establish entities in jurisdictions suitable to hold our overseas investments, giving consideration to our business activities and the prevailing regulatory environment available.

4. Our approach towards our dealings with Her Majesty’s Revenue and Customs (“HMRC”)

We seek to build and sustain relationships with HMRC and other fiscal authorities (where relevant) that are constructive and based on mutual respect. We work collaboratively wherever possible to seek certainty in cases of technical or legal uncertainty with the relevant department of HMRC and to achieve early agreement.

We engage with governments on the development of tax laws either directly or through trade associations and other similar bodies as appropriate including UK tax law.

5. Transparency

We support the principle behind multilateral moves towards greater transparency that increase understanding of tax systems and build public trust.

6. Shionogi group tax policy statement

The Shionogi group tax policy statement can be found here.

Further information

Our approach to tax is applicable across SHIONOGI’s operations in Europe. We review and update this annually.  It was last approved on 23 March 2018. You can email the SHIONOGI European tax team at info@shionogi.eu

This Tax Strategy Statement is effective for the year ending March 31, 2018,  will be updated as required by the Act, and will remain posted at www.shionogi.eu, the website of Shionogi Limited, the UK entity of the Shionogi Group. This tax strategy applies to all UK entities of the Shionogi Group and has been published in accordance with paragraphs 16 and 17 of Schedule 19 of the Act.