UK Tax Risk Strategy

Air Products and Chemicals, Inc. is the ultimate parent of the Air Products’ group. As a United States industrial gas company with global operations, Air Products generates a substantial amount and variety of taxes across its jurisdictions, including (but not limited to) income taxes, stamp duties, employment taxes and indirect taxes such as value added tax.

This tax strategy document applies to Air Products Group Limited and all the UK entities within the Air Products group (the “UK Group”). The publication of this UK strategy statement is regarded as satisfying the requirements of Schedule 19 of the Finance Act 2016. 

This tax strategy document applies to all UK taxes applicable to the UK Group and it is effective for the financial year ending 30 September 2017. The tax strategy statement will be reviewed annually and updated as necessary.

Approach to tax governance and risk management

Operational and governance responsibility for the execution of the Air Products group tax strategy rests with the Vice President, Taxes, supported by a global team of tax professionals. The tax affairs of the Air Products UK group are managed by a UK qualified tax team and external tax expertise is used where necessary. 

The UK Group is within the scope of the UK Senior Accounting Officer (“SAO”) legislation and the SAO is responsible for ensuring the UK Group establishes and maintains appropriate accounting and tax compliance arrangements. 

Air Products complies with all relevant revenue laws, and all taxes are accounted for and paid. Procedures and controls are in place to ensure tax compliance obligations are satisfied.

Given the scale of our business and volume of tax obligations, risks will inevitably arise from time to time in relation to the interpretation of complex tax laws and the nature of our compliance arrangements. In such circumstances, Air Products seeks to identify, evaluate, monitor and manage these risks to ensure that they remain in line with our objectives and are within materially acceptable levels. Where there is a significant uncertainty or complexity in relation to a tax risk, external advice may be sought.

Responsible attitude towards tax planning 

The UK Group does not enter into any aggressive tax planning or support the use of artificial structures that are established solely to avoid paying tax and have no business purpose. The UK Group’s tax planning is aligned with its commercial business and economic activities.

Air Products transfer pricing policy is aligned with the Organisation for Economic Co-Operation and Development (OECD) guidelines as well as the guidelines of the various jurisdictions in which Air Products operates. The prices are benchmarked, taking into account the functions, assets and risks in the various jurisdictions.

Transparent approach to engaging with HMRC

The UK Group engages with Her Majesty’s Revenue and Customs (“HMRC”) in an honest, respectful, transparent, and co-operative manner. The UK Group does not take positions on tax matters that may create reputational risk or jeopardise our good reputation with HMRC. We regularly meet with HMRC in which we discuss tax compliance and reporting, ongoing issues and major transactions.

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