UK Tax Policy

1. Risk Management, Governance and Compliance with UK Tax Laws

Our internal code of conduct clearly outlines the standards all employees must uphold, including compliance with the statutory regulations in their respective jurisdictions, which also extends to tax matters.

The Company remains mindful of its place within an international corporate group, operating under ongoing legislative changes. It recognises the importance of regular training and review of internal policies and procedures to ensure they are effective and appropriate for identifying and managing key UK tax issues.

The Company engages with reputable external advisors who provide compliance services and will also seek appropriate advice in respect of unusual or significant transactions to ensure compliance with tax legislation and policy guidance.

The Company is not solely reliant on those advisors; it also employs a central tax team. The Chief Finance Officer oversees this team, as well as a Board that maintains oversight of UK activities and assumes ultimate responsibility for UK tax matters.

The Company will routinely assess its systems and controls by collaborating with reputable independent advisors to keep pace with changes in tax legislation and effectively manage key tax risks. Additionally, it is committed to meeting all deadlines through thorough internal and external reviews, as well as robust systems and controls.

The Group is focused on what we call “transnational localism.” This approach ensures that the Company emphasizes local employment and will contribute fairly to the UK economy (i.e. jobs, culture and customers). The Company aims to make prompt tax payments and offer upfront disclosure to tax authorities, with input from local tax advisors where required.

2. Our Attitude to Tax Planning

The Zoho Group is committed to managing its affairs in full compliance with the laws of all jurisdictions. The Company takes pride in adopting the same approach as the Group, the Company does not engage in aggressive tax avoidance and is dedicated to ensuring adherence to national tax legislation and international tax guidelines.

The Company does not use abnormal tax structures lacking commercial or operational substance that would be aimed for tax avoidance. The Group’s transfer pricing policy also applies to the UK and is aligned with the OECD guidelines and the regulations of each jurisdiction in which it operates, consistently applying the arm’s length principle.

3. Acceptable level of risk

The Ultimate Beneficial Owners of the Group continue to be the Founders. Their culture of “transnational localism” has remained the core of the expansion strategy and extends to paying appropriate amounts of tax in the right jurisdiction.

Supporting the UK government’s policy objective to combat tax evasion matters to us. The Zoho Group, including the Company, maintains a zero-tolerance policy toward tax evasion and continuously strives to enhance their control of the environment.

The Company manages its tax risk in a conservative manner to ensure compliance with all legal requirements regarding accurate tax payments to the UK and has no interest in artificial transactions that seek to shift profits away from the jurisdiction where the economic activity occurs to one with a lower tax rate.

4. Our Approach towards Dealings with HMRC

The Company maintains an open and transparent relationship with HMRC, based on full disclosure. This approach applies to routine compliance matters as well as significant tax events, which will be openly discussed and appropriately disclosed to HMRC when necessary.

The Company remains attentive to HMRC’s interpretation of the law and its guidance. The Company will seek to resolve any areas of uncertainty by engaging with HMRC, carefully considering legislation and case law, and consulting external advisors as appropriate.