This UK Tax Strategy covers the following entities:
- MUFG Bank, Ltd. – London Branch (the 'Bank')
- MUFG Securities EMEA plc ('MUS EMEA')
- MUFG Funding (UK) Limited and
- MUFG Nominees (UK) Limited
Together the 'Group' for the purposes of this UK Tax Strategy
The members of the Group are all directly or indirectly wholly owned subsidiaries of Mitsubishi UFJ Financial Group, Inc ('MUFG'). 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 Group's tax strategy and tax risk appetite reflect MUFG's vision and values. The Group's tax strategy is to manage its tax position in a manner aligned with its business strategy while seeking to minimise tax risk wherever practicable.
The Group has adopted the UK Code of Practice on Taxation for Banks (the 'Code'), which requires in scope entities to have 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 Bank's tax strategy and tax governance framework in relation to its UK operations rests with the EMEA Executive Committee ('EC') which comprises the Regional Executive Officer and Senior Executives. For the UK legal entities in the Group ultimate responsibility for tax strategy and tax governance framework rests with each company's Board
Responsibility for monitoring adherence to the tax strategy and governance framework rests with the Chief Financial Officer ('CFO'). 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. Tax matters are presented to EC or the Board where appropriate.
The Group's tax compliance position is managed by the 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 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. The tax department will consult with tax management in Japan on matters impacting the wider tax position of MUFG. Risk controls are subject to periodic review by Internal Audit, which reports directly to the Audit Committee of the Bank and Legal entities.
Appetite for UK Tax Risk
The Group's appetite for UK tax risk reflects the MUFG vision and values. Although the Group operates in a complex international sector which by its nature carries a degree of tax risk, the Group 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 Group 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 Group is committed to paying the tax intended by Parliament on its commercial activities. In doing so the Group seeks to obtain tax relief for its business costs and to prevent its income being taxed more than once.
The Group 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 Group 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 Group or for others.
Approach to Dealing with HMRC
In accordance with its Code obligations the Group maintains an open and transparent relationship with HMRC. The Group 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.
UK Subsidiaries
The members of the Group regard the publication of this strategy as complying with the duty under FA 2016 Schedule 19 paragraph 20(2) or 22(2) as appropriate, to publish their sub-group or company UK tax strategy in the financial year ending 31 March 2024.