The tax strategy of salesforce.com EMEA Limited and other UK subsidiaries of salesforce.com Inc (the “UK Group”) is to pay the correct amount of tax, on a timely basis, to the relevant taxing authority. This strategy applies to the UK Group in accordance with its responsibilities under Schedule 19 of the Finance Act 2016 (“the Schedule”) and applies from the date of publication until it is superceded. References to ‘UK Taxation’ are to the taxes and duties set out in paragraph 15(1) of the Schedule which include Income Tax, Corporation Tax, PAYE, NIC, VAT, Insurance Premium Tax, and Stamp Duty Land Tax. References to ‘tax’, ‘taxes’ or ‘taxation’ are to UK taxation.
The strategy, as outlined above, is consistent with the rest of the Salesforce group and also with the Group's Code of Ethics. It is aligned with Salesforce’s broader values, the most important of which is trust. This document is owned by the Board of Directors of salesforce.com EMEA Limited (“the Board”) on behalf of the UK Group. It will be reviewed annually, updated as appropriate and approved by the Board. The Board has delegated responsibility for the implementation of the tax strategy to the salesforce.com , inc. Group Tax and Controllership Teams (“SFDC Tax & Finance”). SFDC Tax & Finance strive to build and maintain relationships across the business to promote and embed the need to take tax compliant business decisions. The in-house group tax function also works to ensure that appropriate and ongoing monitoring of tax risks affecting the UK is performed and adequate mitigation is effected where needed. SFDC Tax & Finance report back to the board on an ongoing basis via the Finance Director and through quarterly tax updates.
The UK Group is committed to compliance with UK tax laws. Compliance, in this instance, means adhering to all relevant UK tax legislation. This legislation covers, inter alia, paying the correct amount of tax to the relevant authority at the appropriate time, disclosing relevant facts and circumstances to the tax authorities and legitimately claiming government reliefs and incentives where available.
In structuring its commercial activities the UK Group will consider, among other factors, local tax laws, with a view to maximising value on a sustainable basis for its partners and employees. Any structuring that is undertaken will give due regard to commercial and economic substance and to the potential impact on the UK Group's reputation and broader goals. SFDC Tax & Finance are staffed by qualified experienced professionals. Due to the increasing complexity of tax laws and the multi-jurisdictional implications of transactions and business operations, SFDC Tax & Finance may seek external advice in certain instances from professional service firms and / or subject matter experts.
Given the scale of business and volume of tax obligations, risks will inevitably arise from time to time in relation to the interpretation of tax laws and the nature of the UK Group's compliance arrangements. The UK Group actively seeks to identify, evaluate, manage and monitor these risks to maintain compliance, minimise financial penalties and protect the business reputation of the UK Group. It seeks to reduce the level of tax risk arising from its operations, as far as is reasonably practicable, by ensuring that due care is taken in relation to processes that affect its compliance with tax obligations. Processes relating to different taxes are assigned to appropriate process owners in SFDC Tax & Finance functions and across the business who review activities and monitor appropriateness and performance of controls. Where there is significant uncertainty or complexity in relation to a risk, external advice may be sought.
The UK Group engages with taxing authorities, including HMRC, with honesty, integrity, respect and fairness. In the event of any inadvertent errors in submissions made to HMRC or other tax authorities, or in interpretation of relevant legislation, appropriate disclosures will be made as soon as possible after they are identified. The UK Group will seek to resolve any disputed matters through pro-active and transparent discussion and negotiation.