MUFG's corporate vision is to be the world's most trusted financial group, and is committed to act responsibly in the best interest of its customers and society as a whole. The Company's tax strategy and tax risk appetite reflect the group's vision and values. The Company's tax strategy is to manage the Company's tax position in a manner aligned with its business strategy while seeking to minimise tax risk wherever
practicable.

The Company has adopted the Code of Practice on Taxation for Banks (the 'Code'), which requires a documented tax strategy and governance process for taxation matters encompassed within a formal policy. Tax governance and management of tax risk Ultimate responsibility for the Company's tax strategy and tax governance framework rests with the Company's Board. Responsibility for monitoring adherence to the tax strategy and governance framework rests with the Chief Financial Officer (CFO), an executive Board member. Day to day responsibility for operating in accordance with the tax strategy and framework rests with the Head of Tax, who reports regularly to the CFO. A report on the Company's overall tax position setting out the Company's tax strategy, how tax affects the Company's business, the main areas of tax risk and how these risks are managed is presented to the Board annually by the Head of Tax.

The Company's tax compliance position is managed by the Company's tax department, staffed by experienced UK tax professionals. Tax aspects of all new business proposals, complex or significant transactions and new products are considered by the tax department as part of the Company's wider new business review framework. Skilled external advice is taken if genuine doubt exists about the tax position, particularly in relation to non UK taxes.

Operational tax risks are monitored and controlled by the Company's operational risk group. Tax risk controls are subject to periodic review by Internal Audit, which reports directly to the Board.

Appetite for UK tax risk

The Company's appetite for UK tax risk reflects the MUFG visions and values. Although the Company operates in a complex international sector which by its nature carries a degree of tax risk, the Company seeks to minimise or avoid tax risk wherever practicable. Documented preventative controls are in place designed to identify tax risk at source and allow its effective mitigation.

Attitude towards UK tax planning

Tax is a business cost. The Company is prepared to consider planning to mitigate this cost, but, in line with its appetite for tax risk, only where this is expressly permitted or envisaged by tax law in the context of genuine commercial activity or to support regulatory policy objectives. The Company accepts it should pay the tax intended by Parliament on its commercial activities. In doing so the Company seeks to obtain tax relief for its business costs and to prevent its income being taxed more than once. Particular reliance is placed on double tax treaties to alleviate double taxation when dealing in overseas securities or with overseas entities. The Company aims to price all transactions with overseas affiliates on the basis of the arm's length standard, interpreted using OECD guidelines.

The Company is not prepared to be party to, or to knowingly facilitate for others, transactions designed to achieve results which do not accord with the aim or intention of tax laws, whether in the UK or overseas. The Company does not provide tax advice, nor design nor promote tax based products to others. Staff are not measured, nor incentivised to act, by reference to tax savings for the Company or for others.

Approach to dealing with HMRC

In accordance with its Code obligations the Company maintains an open and transparent relationship with HMRC. The Company accepts that being treated as low risk by HMRC carries with it a responsibility to be proactive in identifying and bringing potential issues to HMRC's attention. This means that issues of significant tax uncertainty - uncertainty not only about how existing tax law applies to existing transactions, but also uncertainty about how new law is meant to apply in future - are disclosed to HMRC as and when identified, and discussed collaboratively with HMRC to seek their resolution at the earliest opportunity.

Mitsubishi UFJ Securities Holdings Co., Ltd (“MUSHD")

Since 2016 the Company's immediate parent, MUSHD, has operated in the UK through a UK office which constitutes a taxable presence for UK tax purposes, HMRC have agreed that MUSHD's obligation to publish a UK Tax Strategy can be covered within the Company's Tax Strategy.

As with the Company, MUSHD seeks to minimise or avoid UK tax risk, and will only undertake tax planning in line with the intentions of Parliament and genuine commercial activities. Responsibility for MUSHD's UK tax governance ultimately rests with MUSHD's CFO, but day to day management of its UK tax affairs is managed by the Company's tax department, who seek to maintain an open and transparent relationship with HMRC regarding MUSHD's UK tax matters.

MUSHD's UK operation ceased during 2018 after which it no longer had a UK tax presence.

The Company and MUSHD regard the publication of this strategy as complying with each company's duty under FA 2016 Schedule 19 paragraph 22(2) to publish a tax strategy in 2018.