UK Tax Strategy

This UK Tax Strategy covers the following entities:

• Link Group Administration Ltd
• DF King Ltd
• Orient Capital Ltd
• Link Treasury Services Ltd
• Link Market Services Ltd
• LF Solutions Holdings Ltd
• Link Market Services Trustees Ltd
• Link Fund Solutions Ltd
• Link Pension Administration Ltd
• Link Pension Administration (HS) Pensions Ltd
• Link Group Service Company Ltd
• Link Share Plan Services 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.

MUFG 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.

1. Background

This UK tax strategy has been prepared in accordance with the Group’s Tax Risk Governance Policy (https://www.linkgroup.com/docs/LG-Tax-Risk-Governance-Policy.pdf) and, as such, is implemented with the consent of the MUFG Pension and Market Services Holdings Limited Board of Directors. This strategy is managed by the Group’s Tax function and is subject to periodic review. The UK tax strategy forms part of the MUFG Pension and Market Services (stream of the MUFG wider group) five strategic pillars of:

• Growing with our clients in attractive markets
• Product and service innovation
• Client, product and regional expansions
• Integration and efficiency benefits
• Identifying adjacent market opportunities

2. Managing tax risks

As outlined in the Tax Risk Governance Policy, the Group is committed to transparently complying with and disclosing all its tax obligations and payments made. Further, the Group focuses on integrity in compliance and reporting and engaging with tax authorities.

The Tax Risk Governance Policy outlines roles and responsibilities in respect to tax risk management. As part of Management, the Group Head of Tax is responsible for implementing the tax strategy and developing the procedures to support, maintain and ensure the Tax function has the necessary skills to implement the strategy. The Group Head of Tax reports to the Group Financial Controller, who in turn reports to the Group Chief Financial Officer.

The UK tax strategy is managed through:

• Financial and operational reporting which identifies key risks, with tax risks to be mitigated and signed off by the Group Head of Tax
• All tax filings are reviewed (if not prepared) by the Tax function prior to lodgement, undergoing a four-eyes review to ensure accuracy
• Providing timely, relevant and accurate tax advice to business units/divisions; and
• All projects, significant business transactions, entity incorporation requests and financial system configurations require approval from the Group Head of Tax and all material matters are reviewed by Group Chief Financial Officer.

The Group uses external advisors on a selective basis to prepare and review tax filings, advise on operational matters and complete due diligence on acquisitions, in accordance with established procedures and in consultation with the Group Chief Financial Officer. Further, tax is discussed in local risk committees and Group’s Risk and Audit Committees.

3. Tax risk appetite

The Group has a low-risk appetite in respect to taxation in accordance with the Tax Risk Governance Policy and does not operate complex tax structures. Provided the tax risk of a transaction is within the low tax risk appetite, the Group seeks clarity within the law and evaluates the potential tax outcomes of operations or corporate group activities. Where tax risks are identified, mitigation to achieve a low-risk outcome is advised and this forms part of the Group’s reporting to the Risk and Audit Committee.

4. Tax planning

The Tax Risk Governance Policy states that the Group does not sanction or support any activities which seek to aggressively structure tax affairs. The Group specifically:

1. Does not artificially shift and/or accumulate profits in low tax jurisdictions.
2. Does not use the secrecy rules of jurisdictions to hide assets or income.
3. Pays tax where the underlying economic activity occurs.
4. Applies carried forward tax losses where tax legislation enables Group to do so.

The Group does implement efficient tax planning to support the business and reflect the commercial and economic activity, in accordance with the low tax risk appetite.

Further, the Group does not sanction any activities which directly or indirectly facilitate or enable the evasion or aggressive avoidance of tax by its clients, employees, contractors, suppliers or other associated parties with whom it does business.

5. Relationships with tax authorities

The Group maintains open, clear, honest and positive working relationships with tax authorities and regulators around the world. All correspondence with tax authorities is handled by the Group Tax function or qualified tax personnel in operating units/ divisions of the Group (e.g. Client taxation teams).

All tax authority audits are reported to the Group Head of Tax or the Group Chief Financial Officer. The relevant local board of directors and local risk committees are informed of tax audits. When necessary, particularly for material correspondence, the Group Risk and Audit Committee will also be advised.

The UK tax strategy has been prepared to comply with paragraph 16(2) Schedule 19 of the Finance Act 2016 and applies for the year ended 30 June 2024.