Dyson Automotive Research and Development Ltd – Tax Strategy
1. Introduction
Dyson Automotive Research and Development Ltd (the “Company”) is part of the Dyson Group (the “Group”). The Company is not actively trading and is in the process of a members’ voluntary liquidation. The Group is headed by Dyson Holdings Pte Ltd and is headquartered in Singapore. The Group’s principal activity is the development of new technology and the manufacture and sale of products incorporating that technology. The Group is subject to tax in various countries and under different tax regimes.
2. Tax planning strategy
Dyson Holdings Pte Ltd has a documented code of conduct, to which all companies in the Group must adhere. Amongst the principles enshrined in it are compliance with the law and with ethical standards. All staff are required to follow these principles in all dealings relating to tax.
The Group ensures that all its tax obligations are met and seeks to ensure that tax is paid where and when it is due. The Group interprets tax laws in the way it believes they were intended to apply and does not seek to use the tax laws in a contrived manner. It expects tax authorities to follow the same principle.
The Group deal with cross-border tax matters in accordance with the terms of any relevant tax treaties and OECD guidelines.
3. Relationships with tax authorities
The Group works collaboratively with tax authorities. Where the amount of tax due is subject to a significant degree of uncertainty, the Group actively engages with the relevant tax authorities and where appropriate seeks binding rulings. By working with local tax authorities, through an open relationship, the Group increases certainty over its tax affairs.
Due to the complexity of tax legislation, the Group and tax authorities may occasionally have differing opinions of the treatment of certain tax items. Where this is the case, the Group works with that tax authority to reach resolution as promptly as possible.
4. Tax risk management
The Group’s risk management (which includes tax risks) is overseen by the Board, supported by the Group Risk Committee and Group Audit Committee (the latter in terms of financial internal controls).
The Group Risk and Internal Audit functions report to the Group Risk Committee and Group Audit Committee respectively.The Group maintains an up-to-date register of tax risks. All material tax risks are discussed with the Group Risk and Internal Audit functions 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 Group manages them are:
a) Complexity and changes in legislation – The Group is subject to tax in many countries across the world, each of which has its own set of complex tax legislation. Such legislation is typically updated on an annual basis. To keep up with these changes, the Group ensures that its tax functions have access to tax updates, access to specialist training and opportunities to obtain professional tax qualifications. The Group also utilises the services of external tax advisors as and when required.
b) Compliance and reporting risk – The Group is required to meet many different tax compliance and reporting obligations across the world. If these are not complied with, the Group could suffer penalties and interest. The 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 Group’s approach to tax. As part of the annual financial reporting process, the CFO communicates relevant information on the Group’s tax position to the Board of Directors.
The responsibility for the day-to-day management of the Group’s tax operations is devolved to the internal tax functions, 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 tax position of a particular matter.
6. Total Tax Contribution (“TTC”)
The Dyson Holdings Pte Ltd approach to tax is applicable to all group companies. The tax strategy is reviewed and updated annually. This document complies with the Group’s UK subsidiaries’ duty under Paragraph 19(2) of Schedule 19 of the Finance Act 2016 to publish a tax strategy in respect of the period ended 31 December 2024.
Approved by: Andrew Duckett, Group Tax Director
On behalf of Dyson Automotive Research and Development Limited’s Board of Directors
Date: December 2024
