Stannah Lifts Holdings Limited and subsidiary companies
Policy on Tax risk management and strategy

High Level Overview

The Stannah Group is a multinational business with subsidiaries and branches in a number
of countries.

The Group has strategic tax objectives focused in the following areas

  • Compliance – for tax jurisdictions where an obligation arises on a Group organisations; to
    submit all appropriate tax returns and pay amounts of tax due within the statutory
    deadlines.
  • Tax risk management – to prevent disputes with Revenue authorities, wherever they may
    potentially arise. To only take a position in our computations where it would be more
    likely than not that the Revenue would accept this as being an appropriate interpretation
    of the tax law.
  • Commercial objectivity – we will structure transactions to suit their commercial rationale.
    Where there is a choice on how to structure the transaction, we will consider the tax
    impact but we will not enter into a transaction solely for a tax benefit.

Governance

The Board of Directors (“BoD”) of the Company acknowledges its obligation for fully
complying with all relevant tax laws effective for the jurisdictions in which Group
organisations operate. Approval of tax strategy is, ultimately owned by the BoD but
effectively delegated to the Group Financial Director (“GFD”).

The GFD shall ensure a suitably competent resource is available to meet the objective of the
BoD in each jurisdiction in which a Group organisation has a tax obligation. The GFD shall
delegate compliance responsibilities to that suitably qualified resource for the purposes of
delivering accurate Tax Returns on behalf of Group organisations.

Strategy delivery

The framework below underpins how the strategic tax objectives will be delivered:

Compliance

  • The Group Tax Department (“GTD”) shall understand the compliance obligations in each
    jurisdiction, and know how those obligations are to be fulfilled.
  • For each Tax Return dealt with directly by GTD there will be in place a robust review
    process. For Returns dealt with by third party advisors GTD will assess whether the
    abilities and competences of the advisors appointed may reasonably be expected to be
    of a standard necessary to meet Group compliance needs in the jurisdiction concerned.
  • Competent external advisors shall be used to confirm or advise upon technical positions
    and legal understandings when required.
  • All material positions taken in the Tax Returns shall be made explicit to the person
    approving the Return and be supported by comprehensive documentation, and
    disclosure in the Return when appropriate.

Tax risk management

  • Group accounting policies shall take account of applicable tax law in their construction
    and execution.
  • GTD shall maintain a current awareness of applicable tax law and the progressive
    development of that law inasmuch as it does or may in the future apply to Group
    operations. Training of Tax staff shall be directed towards achieving this.
  • Employees involved with transactions that have relevance for accurate completion of Tax
    Returns shall be trained to be aware of the reporting requirements and obligations
    related to those transactions.
  • GTD will provide a robust audit process to ensure the accuracy and consistency of the
    Returns with which it deals. Wherever and whenever practicable it will review and
    question Returns that have been constructed by the staff or advisors of organisations not
    resident in the UK.
  • Group companies shall ensure GTD is involved in any new or developing business
    activities or ventures to enabling all tax compliance and reporting consequences to be
    considered and understood, with appropriate provision made for reporting data for Tax
    Returns.
  • All issues and uncertainties outside of the competences of GTD shall be referred to
    suitably qualified third party advisors.
  • Group companies (and their advisors) shall foster good relationships with their Revenue
    authority and undertake all such dealings with said authority in a professional, courteous
    and timely manner.

Commercial objectivity

  • Advice sought and or obtained from third party advisors shall be relevant only to the
    commercial rationale of the Stannah operation concerned in respect of the jurisdiction in
    which it operates. A Stannah operation’s relationship with other Group organisations
    outside its operational jurisdiction will be considered only inasmuch as it is necessary to
    ensure the OECD arms length principle is maintained, such as for setting transfer prices.
  • It is not the objective of the BoD to minimise the level of tax paid by Group organisations
    below that, which the law of the jurisdiction in which it operates, reasonably allows for.

Review and Application

This document is periodically reviewed for its relevance to the current financial year by the
GTD with any amendments considered and approved by the BoD through the GFD. This
policy has been reviewed and approved effective for the Financial Year ended 31 December
2019.