Policy
Egmont is committed to:

• be fully compliant with tax laws across all relevant jurisdictions.
• ensure paying the tax we are legally required to pay in all the countries in which we operate.
• apply tax incentives in the manner intended by governments and fiscal authorities.
• conduct transactions between group companies on an arm’s length basis and in accordance with OECD principles.

Tax, for these purposes, includes taxes directly imposed on our operations, e.g. corporate income taxes, as well as taxes collected on behalf of governments, such as VAT, employee taxes and other withholding taxes.

Governance
The Board of Trustees reviews the tax policy annually.

The tax policy aligns to the way Egmont works with risk and controls in a wider perspective.

The Chief Financial Officer (CFO) is overall responsible for implementation of the tax policy and management of tax risks. The Head of Corporate Accounting and Controlling has the day-to-day responsibility. Key risks and issues related to tax are considered by the Board of Trustees. Egmont actively seeks to identify, evaluate, monitor and manage tax risks to ensure they remain in line with objectives. We are continuing to improve our tax governance.

Tax risk management
Egmont is exposed to a variety of tax risks:

• Tax compliance and reporting risks – Risks associated with compliance failures such as submission of late or inaccurate returns and the failure to submit claims and elections on time.
• Transactional risks – Arising where transactions are carried out or actions are taken without appropriate consideration of the potential tax consequences or where advice taken is not correctly implemented.
• Reputational risks – Non-financial tax risks that may have an impact on relationships with stakeholders, including tax authorities and the general public.

Tax risks may arise because of:

• Complex and/or unclear legislation.
• Lack of skills.
• Insufficient finance or operational systems and processes.
• Lack of timely involvement of relevant internal and/or external expertise in business decisions.
• Insufficient tax due diligence in respect of acquisitions.

Egmont aims to manage tax risk in a similar way to any area of operational risk across the group.

Where appropriate, Egmont looks to engage with tax authorities to disclose and resolve issues, risks and uncertain tax positions. The subjective nature of many tax rules does, however, mean that it is often impossible to mitigate all known tax risks.

Tax compliance and relationship with tax authorities 
Egmont is committed to calculate all taxes correctly in accordance with the law and pay them when due. Statutory tax returns for all taxes should be filed correctly, contain accurate information and be filed on a timely basis. All other tax obligations in the jurisdictions in which Egmont operates should be fully complied with as well.

There is no prescriptive level of tax risk which Egmont is prepared to accept, but the aim is to minimise the risk as far as possible.

Egmont seeks to maintain open and transparent relationships with the tax authorities and other relevant bodies in the jurisdictions in which we operate. Any errors or mistakes in tax returns will be fully disclosed and notified to the relevant tax authority as soon as practicable. Enquiries raised by tax authorities will be dealt with on a timely basis, answered in an open way with a full response to the enquiry. Advance tax clearance of key transactions will be obtained where tax treatment is uncertain, and a tax clearance procedure is available.

Egmont use best efforts to comply with the requirements under the mandatory automatic exchange of information rules contained in European Council Directive (EU) 2018/822 (DAC6)

Tax planning
Egmont recognises the responsibility to pay the correct amount of tax in each of the jurisdictions in which it operates.

Egmont do not accept aggressive tax planning and seeks to implement structures that are sustainable in the long term. Egmont defines aggressive tax planning as exploitation of technicalities in a tax regime or as inconsistencies between tax regimes in order to reduce tax liability.

In implementing sustainable business structures, Egmont will ensure that its tax position supports the business, reflects genuine commercial activity and complies with applicable laws and regulations. The business only carries out tax planning to the extent it reflects the commercial activity of the business and is not undertaken for artificial/purely tax motivated reasons. In the spirit of the law, Egmont may, however, seek to benefit from legislative reliefs or incentives such as capital allowances and tax deduction for charitable donations. And in general, we try to avoid double taxation. Upon acceptance of tax incentives or reliefs offered by governments, Egmont will ensure that the incentives implemented are in line with the intent of the incentives offered.

External advice may be sought in relation to tax planning or areas of complexity or uncertainty to support Egmont in complying with its tax policy.

Transactions between group companies are conducted on an arm’s length basis in accordance with appropriate transfer pricing rules and OECD principles. This ensures that Egmont’s global profits are properly allocated to the jurisdiction in which those profits are generated based on sound commercial activities.

Restricted jurisdictions
Egmont support increased transparency and the international initiatives that are implemented at OECD and European level towards increased transparency. In line with these principles, Egmont use caution when investing in portfolio companies and by not investing in companies incorporated or tax resident in:

1. Jurisdictions that are deemed “not compliant” according to OECD’s Global Forum in Transparency and Exchange of Information for Tax Purposes peer review process at the time of the investment, or 
2. Jurisdictions listed on the EU’s list of non-cooperative tax jurisdictions at the time of the investment

International developments and transparency
Egmont continuously monitor international tax legislative developments and initiatives promoting responsible tax behaviour and transparency for taxes, Egmont will comply with the international initiatives implemented such as the OECD initiative on global minimum taxation (Pillar II). Egmont provides information about Egmont’s tax position in accordance with regulatory requirements and monitors international initiatives to promote tax transparency.

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Regarding Egmont’s companies incorporated in the UK:

Egmont regards our publication of this tax policy as complying with the duty under paragraph 16(2) Schedule 19 Finance Act 2016 to publish a tax policy for the financial year ending 31 December 2023.

Companies covered by this tax policy:

• Egmont Holding Limited
• Story House Egmont Ltd.
• Egmont Publishing Ltd.
• Avalanche Studios Group Ltd.
• Supermassive Games Ltd.
• Supermassive Games 1 Ltd.
• Supermassive Games 2 Ltd.
• Supermassive Games 3 Ltd.
• Starshape Games Ltd.
• S360 Digital UK Ltd.