This UK tax strategy for Mindray UK Limited (‘Company’ or ‘Mindray UK’) is published in accordance with the requirements set out in Schedule 19 of Finance Act 2016. This tax strategy, which has been approved by the Board of Directors, is effective for the year ending 31 December 2020.
Mindray UK provides healthcare solutions including the supply of patient monitoring systems, ultrasound imaging and anaesthesia. A significant proportion of Mindray UK’s product sales are through contracts with the National Health Service. Mindray UK’s ultimate parent entity is Shenzhen Mindray Bio-Medical Electronics Co., Ltd., incorporated in the People’s Republic of China.
Approach to Tax Risk Management
Mindray UK has adopted and developed a tax strategy as devised by the Group. This global strategy amounts to the compliance of each of their subsidiaries with local tax legislation. Mindray UK seeks to implement this UK tax strategy through the utilisation of the Group’s in-house tax professionals and through their engagements with external professional advisors.
Mindray UK’s Chief Financial Officer (‘CFO’) is charged with the oversight of tax compliance, including the assessment of tax risk that the business faces within the UK.
Mindray UK is liable to a range of taxes in the UK including corporation taxes, VAT and employment taxes (PAYE, NIC, apprenticeship levy as well as business rates. Mindray UK seeks the assistance of external advisors who are engaged to advise on changes in legislation deemed relevant to Mindray UK’s tax affairs and to assist with more complex tax compliance requirements. Mindray UK appoints external professional advisors to assist with the preparation and timely submission of corporation tax computations and returns.
Internally, work undertaken in relation to tax compliance is carried out by ACCA or ICAEW accredited (or with equivalent professional qualification) staff members who are appropriately trained and qualified to perform their function. Where necessary, advice is sought from external professional advisors.
Attitude to Tax Planning
Mindray UK considers its approach to tax planning as conservative and so would not engage in tax planning arrangements that are, or could be perceived as being, artificial or contrived. This aversion extends to arrangements that seek to utilise any legislation in a way contrary to the intention of Parliament.
For Mindray UK, business continuity is of foremost importance. In the previous 12 – 24 months this approach has resulted in Mindray UK being proactive and undertaking risk assessments to identify and mitigate any potential interruptions as a direct result of Brexit.
Mindray UK’s attitude to claiming allowances and tax relief is do so when in line with UK legislation and the business’ commercial operations. Mindray UK operates in a way in which their commercial objectives are aligned to meet their legal obligations in an ethical manner.
During the COVID-19 Pandemic, Mindray UK has not made use of any government led grants or business relief schemes and has made all VAT payments on time despite the UK government’s offers of deferred payments. These decisions are in line with Mindray UK’s values in the business’ wish to confer the economic benefits of their operations to the communities in which they operate.
In addition to other training, Mindray UK mandates that all employees complete Anti-Money Laundering and Anti-Bribery and Corruption training upon their employment. This is administered by the internal HR team with compliance recorded electronically.
Regarding the transfer pricing of intercompany transactions, Mindray UK adopts the approach and the methods recommended by the OECD Transfer pricing Guidelines and is compliant with the laws of the relevant jurisdictions. The Group strives to comply with local transfer pricing legislation in every jurisdiction they operate, i.e. filing of the local files and the master file. The Group is compliant with their Country-by-Country Reporting (“CbCR”) and CbCR notification requirements. These examples support the Group’s objective to support transparency and cooperation with local governments and stakeholders.
Level of Tax Risk for UK Taxation
Mindray UK adopts a risk-averse and prudent approach regarding their tax affairs. Mindray UK adheres to their tax obligations and adopts a risk-averse approach in alignment with their core values. Mindray UK demonstrates through their business operations that being a responsible taxpayer is a priority area for management.
Approach to Working with Tax Authorities
Mindray UK is committed to complying with tax laws in a responsible manner and to having open and constructive relationships with HMRC. Mindray UK aims to act in a transparent and cooperative manner when dealing with HMRC, ensuring compliance to UK tax legislation. This includes maintaining a contemporaneous and robust system of statutory record-keeping.
The Company will raise matters with HMRC through its professional advisors, where it seeks to obtain clarity about uncertain tax matters and/or obtain advance clearance in respect of intended filing positions.
General Manager – Mindray UK