Introduction

This document, approved by the Board of Aramex (UK) Limited (‘Aramex UK’), is published to set out Aramex UK’s policy and approach to conducting its UK tax affairs and dealing with UK tax risk. The document will be periodically reviewed by the Aramex UK and Aramex Group Tax team, and any amendments will be approved by the Aramex UK Board of Directors. The company regards its publication as complying with the duty under paragraph 22(2) of Schedule 19 to Finance Act 2016 for the year ending 31 December 2018.

Aramex UK’s Tax Policy

Aramex UK is committed to:

1. Complying with all relevant laws (including the OECD arm’s length standard with respect to transfer pricing), rules, regulations, and reporting and disclosure requirements, relating to its activities.
2. Applying professional diligence and care in the management of the processes and procedures by which all tax related activities are undertaken, and ensure tax governance and assurance procedures are appropriate.
3. Maintaining constructive, professional and transparent relationships with tax authorities, based on integrity, collaboration and mutual trust.
4. Using relevant incentives, reliefs and other tax planning to minimise the tax costs of conducting its business activities, but will not use them for purposes which are knowingly contradictory to the intent of the legislation.

Aramex UK Tax Code of Conduct

This Tax Code of Conduct (CoC) outlines the principles setting out how Aramex UK employees are expected to operate with respect to tax matters in support of the above Tax Policy. Non-adherence to this CoC could constitute a disciplinary matter.  The Tax CoC is set out in detail below.

A. Compliance with laws, rules and regulations

Aramex UK is committed to observing all applicable laws, rules, regulations, and reporting and disclosure requirements, wherever there is a requirement to do so. 

Aramex UK and Aramex Group Tax team will collaborate with Aramex UK’s businesses to provide advice and guidance necessary to ensure compliance, obtaining external advice where necessary. There are clear management responsibilities, backed up by regular monitoring and review, carried out by Aramex Group Tax team with the necessary experience and skill set.

B. Governance, Assurance and Tax Risk Management

Managing Aramex UK’s tax affairs is a complex and continuous process across many functional areas of the business and as such there will inevitably be risks of error or omission within those processes (Tax Risks) which may result in the incorrect application of tax rules or calculation of tax returns. Eliminating tax risks entirely is impossible, therefore Aramex UK’s attitude towards the level of control required over the processes designed to reduce these Tax Risks is driven by the likelihood of occurrence and scale of impact of each Risk.

The identified Tax Risks are then assessed on a case by case basis, allowing Aramex UK to arrive at well‑reasoned conclusions on how each individual Risk should be managed. Where there is uncertainty in how the relevant tax law should be applied, external advice may be sought to support the Group’s decision-making process.

When reviewing the Tax Risks associated with a specific decision or action, the Group ensures that the following are considered:

• The legal and fiduciary duties of directors and employees.
• The requirements of Aramex Code of Conduct and related policies or procedures.
• The maintenance of the Group’s corporate reputation, having particular regard to the Aramex’s Core Values regarding the way we interact with the communities around us.
• The tax benefits and impact on Aramex UK’s reported result comparative to the potential financial costs involved, including the risk of penalties and interest.
• The wider consequences of potential disagreement with tax authorities, and any possible impact on relationships with them.

Aramex UK may employ various risk management processes and systems to provide assurance that the requirements of the Tax Policy are being met. The Board of Aramex UK does not accept high levels of risk in relation to UK taxation.

C. Relationships with tax authorities

Aramex UK is committed to the principles of openness and transparency in its approach to dealing with the HMRC and other taxation authorities, including OECD measures on country by country reporting and exchange of information. All dealings with the HMRC and other relevant bodies will be conducted in a collaborative, courteous and timely manner. The aim would be to strive for early agreement on disputed matters, and to achieve certainty wherever possible.

In particular, in its dealings with HMRC, Aramex UK commits to:

• open and collaborative professional relationships at all times with HMRC;
• full, open and early dialogue with HMRC to discuss tax planning, strategy, risks and significant transactions;
• making fair, accurate and timely disclosure in correspondence and returns, and responding to queries and information requests in a timely fashion;
• transparency around decision-making, governance and tax planning;
• structuring transactions to give a tax result which, to the best of the company’s belief, is not inconsistent with the economic consequences (unless specific legislation anticipates that result), nor contrary to the intentions of Parliament; and
• interpreting the relevant laws in a reasonable way, and ensure transactions are structured consistently.

D. Tax incentives and reliefs

Aramex UK believes that it should pay the amounts of tax legally due in the United Kingdom. There will, however, be circumstances where this amount may not be clearly defined, or where alternative approaches may result in differing tax outcomes. Aramex UK will use its best judgement in determining the appropriate course of action, using available reliefs and incentives where possible and will seek professional advice as appropriate in accordance with its governance policy.