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Tax Strategy Statement

Last Update: October 2023

Tax Strategy

This document has been approved by the directors of Trayport Holdings Limited, Trayport Limited and TMX Exchange Services Limited as of October 2023. This strategy has been published in accordance with part 2, schedule 19, paragraph 16 of the Finance Act 2016 and relates to the accounting period ended 31 December 2022. This document sets out the strategy for Trayport Holdings Limited, Trayport Limited (100% subsidiary of Trayport Holdings Limited) and TMX Exchange Services Limited (collectively “the Group”). All Group companies are controlled by the same ultimate controlling entity.

The Group’s UK tax strategy forms part of our wider corporate governance and reporting strategies and considers the Group’s corporate reputation in line with its overall standards of governance, core ethical behaviours and values.

UK tax risk management

It is the Group’s policy that all tax positions taken are conservative and consistent with its core principles which include taking a considered attitude to risk in order to protect its stakeholders. The Group employs a tax manager to oversee all areas of taxation. The tax manager’s role is to assist in ensuring tax obligations are met and areas of risk are identified and addressed where possible. The Group complies with internally set policies and procedures in relation to tax risk management and conducts risk assessments before entering into any material ventures or initiatives. External advice is sought, where appropriate, to support conclusions reached by the tax manager.

The objective of the Group is to minimise any tax-related risks by means of appropriate mitigation measures. Material tax risks are included in the Group’s risk register and are reviewed when there are significant business or legislative changes. More detailed information on the Group’s risks can be viewed in the “Risks to the business” section of Trayport Limited’s Annual Report 2022.

Tax Planning

The Group undertakes tax planning to support the commercial needs of the business by ensuring that its affairs are carried out in a tax efficient manner whilst remaining compliant with all relevant laws. The tax manager is therefore involved in material commercial decision-making processes and provides appropriate input into new ventures and initiatives to ensure a clear understanding of the tax consequences of any decisions made.

In instances where the tax legislation and guidance are considered to be unclear or the Group does not consider it has the necessary expertise to assess the consequences adequately, external advice is sought to support the decision-making process.

Risk Appetite

The Group’s position with respect to tax planning and risk management is generally to take a conservative approach, aiming to comply with relevant tax law, rulings and case law. The Group seeks to balance tax risk by maintaining a vigilant and robust oversight of the tax reporting processes and by taking third-party advice in areas of particular complexity.

Working with HMRC

The Group recognises the importance of maintaining a good working relationship with HMRC.

Therefore, the Group aims to ensure transparency is maintained by:

  • engaging with HMRC in an open, constructive and professional manner;
  • delivering information through the normal compliance processes in a timely manner;
  • seeking to resolve any queries raised by HMRC by promptly providing readily available supporting information; and
  • providing full disclosure in respect of any material or tax sensitive aspects of any tax submission.

Download Tax Strategy Statement