Sivantos Limited (“Sivantos UK”), a UK-resident company, distributes a comprehensive range of digital hearing instruments and software, patient management systems and audiology equipment to the National Health Service, independent retail dispensers and national retail chains in the UK.
Sivantos UK is a member of the WS Audiology group of companies (“WSA” or “the Group”) which is headquartered in Denmark and Singapore. WSA is active in over 125 markets and employ over 11,000 people worldwide.
Risk management and governance in relation to UK taxation
Sivantos UK has an experienced finance team which manages UK tax matters for the company. This team engages the services of professional advisers in relation to both corporation tax and VAT matters on a regular basis. External professional advisers prepare Sivantos UK’s annual corporate tax returns and quarterly VAT returns. The administration of payroll taxes is outsourced to a specialist external service provider.
Sivantos has a global head of tax, employed by Sivantos Pte Ltd (“Singapore Singapore”), who oversees international tax matters on a group-wide basis and who reviews Sivantos UK’s corporate tax reporting. The global head of tax is responsible for reporting Group tax matters to the Board of WSA.
Attitude towards tax planning
At a group level, WSA strives to comply with all applicable regulations and disclosure obligations in the territories where it operates and to ensure all interaction with tax authorities is conducted in a transparent and professional manner.
The Group adopts a conservative approach to managing tax risk and only engages in transactions that have a sound commercial basis. The Group’s global tax function in Sivantos Singapore takes professional advice on any complex tax matters that may arise or where there is any doubt in relation to the interpretation of tax law.
The Group’s global tax function regularly reviews the pricing of cross border transactions within the Group to ensure that intra-group transactions are at arm’s length, in accordance with the principles of the OECD Guidelines for transfer pricing.
Acceptable level of risk in relation to UK taxation
Sivantos UK has a conservative approach to managing UK tax matters. As a UK-focused distribution business, Sivantos UK does not have complex tax affairs. In the case that Sivantos UK were to have any doubt in relation to UK taxation, the company would consult the Group’s global tax team and/or external professional advisers.
Approach to dealing with HMRC
Sivantos UK aims to have a transparent and cooperative relationship with HMRC. In the event of a query from HMRC, the company would respond in a timely manner and endeavour to work actively with HMRC to punctually resolve any open matters. Furthermore, Sivantos UK would consult with HMRC with regards to any areas of uncertainty in the interpretation of UK tax legislation that may arise.
This tax strategy is published to meet the requirements of Schedule 19, the Finance Act 2016, for the year ended 30 September 2020.