Our approach to tax in the UK
This document regarding our approach to tax in the UK is published by NTT DATA EMEA Ltd on behalf of its UK affiliates as listed in the Appendix A in accordance with the requirements of paragraphs 19(2) and 22(2) of Schedule 19 of the UK Finance Act 2016. This document is effective for the financial year ending 31 March 2020 and will be reviewed annually and updated as necessary.
Our Business Overview
We are one of the leading information technology businesses specializing in systems integration, with a broad range of related services that includes consulting, network development, and custom software development. We also offer internet access, intranet development, and e-commerce services, including electronic banking, information processing, multimedia content creation and sales, and advertising services.
Our approach to tax risk management and governance
We are committed to highest ethical standards and compliance with all relevant laws and regulations, social standards, and internal business policies.
Our business is overseen by the Chief Finance Officer (“CFO”) of NTT DATA EMEA Ltd, who is supported by other UK affiliates’ CFOs and experienced finance teams. Each CFO’s responsibilities include risk management, governance and oversight with respect to tax. Reporting to our CFOs, our finance and tax teams ensure that robust tax administration (including timely filing of tax returns, making of tax payments and prompt dealings with any queries from Her Majesty’s Revenue and Customs (‘HMRC’)) is maintained.
We maintain policies of internal control systems as approved by senior management of the business to deal with various risks including tax. Our business is subject to Senior Accounting Officer (‘SAO’) obligations, and our SAO is responsible for ensuring that our tax accounting arrangements are appropriate. Our SAO therefore plays an important role in achieving our tax strategy by having an oversight over our relevant tax processes and controls.
As part of the overall risk management and governance arrangements, our business is also supported by external advisors, where necessary.
The level of tax risk we are prepared to accept
We have a low tolerance towards tax risks, and we are committed to maintaining and enhancing our tax compliance processes and controls by ensuring that appropriate training and guidance are provided within our finance and tax teams.
Our approach to tax planning
The UK Affiliates business undertakes business transactions in a way that may include the claiming of statutorily available reliefs, exemptions and / or incentives that are consistent with the UK tax legislation, with a view to maximizing the shareholder value of our business. In addition to the above, tax advisors are consulted in advance on complex points of law and / significant transactions. We do not implement any tax planning measures which are artificial in nature and does not reflect our business reality.
Our approach to dealings with HMRC
We aim to maintain a good relationship with HMRC and work collaboratively. Particularly, UK Affiliates business is committed to open, collaborative, professional and transparent relationship with HMRC. This is achieved by regular discussions about the business, business developments and any tax matters. We have implemented appropriate internal processes to ensure any tax submissions and communications with HMRC are accurate and timely.
Approved by NTT DATA EMEA Ltd. Board on January 7th 2020.
Appendix A – UK Affiliates
NTT DATA EMEA Ltd
NTT DATA UK Ltd
NTT DATA UK Consulting & IT Solutions Ltd
Inventif RMA Holdings Ltd
RMA Consulting Ltd
Keane Pension Trustees Ltd