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How we arrange our tax affairs

HCA UK is committed to paying all relevant taxes in the UK, complying with all applicable UK tax laws and filing obligations. We maintain an open, honest and proactive relationship with HMRC. In advance of making a tax based decision, including as regards to any planning, HCA UK will consider, among other factors, the commercial purpose and the strength of its external tax advisor’s opinion in order to determine whether the tax risks presented by that decision are acceptable.

How we manage our tax risks

Our approach to tax risk is based on principles of reasonable care and materiality. Tax risks are assessed on a case by case basis considering their impact and likelihood, and are escalated via the appropriate levels of management, ultimately to the UK Board. Where there is uncertainty in interpreting the relevant tax law, external advice may be sought to support our decision making process. The HCA UK tax team works alongside the finance and legal functions to provide appropriate input into business proposals to ensure a clear understanding of the tax consequences of any decisions made. We continually improve the efficiency of our business functions by ensuring that we have experienced personnel, adequate resources and expertise, and using market leading technology which supports our tax and financial reporting. We also have regular training in order to develop tax awareness across our business functions. Effective risk management is paramount for HCA UK and underpins our business strategy. Our appetite for risk is a carefully calibrated part of the business model aligned to our strategic and corporate objectives, and considering the factors outlined above. Our reputation and brand are very important to us, and we have a low tolerance for transactions which have the potential to damage these. In determining our tax risk tolerance, we consider the interests of our key stakeholders, such as consumers, customers, and other third parties with whom we operate in partnership.

Our relationship with HMRC

We are committed to having an open, honest and proactive relationship with HMRC. We maintain a regular dialogue with HMRC covering all areas of UK taxation. We seek to obtain advance clearances where tax treatments are uncertain and discuss contentious issues with HMRC in advance of filing where appropriate. We ensure that our tax returns include full disclosure of significant transactions. We rigorously review our tax returns and other filings. In the event of errors being identified, we work collaboratively with HMRC in order to resolve these as soon as possible. This document was approved by the UK Board, on 14 December 2017 and will be reviewed annually. Footnote: This tax strategy applies to our UK sub-group headed by HCA UK Holdings Ltd together with the following entities, SCRI Global Services Ltd and Health Trust Europe Company Ltd and has been published in accordance with paragraphs 19(2) and 22(2) of schedule 19 of the Finance Act 2016. It applies to our accounting period ended 31 December 2017. It reflects the policy and principles for the management of all taxes including corporation tax, PAYE, VAT, insurance premium tax, stamp duty land tax, stamp duty reserve tax, customs and excise duties, employee taxes and withholding taxes.

Overview of our business in the UK

HCA Healthcare UK (‘HCA UK’) provides private healthcare across London and Manchester, with 800,000 patient interactions every year. From complex and urgent care, to primary care, outpatient and day-case treatment, we aim to provide exceptional care across our network of facilities and key NHS partnerships. HCA UK employs more than 5,000 people in the UK.

How we manage our tax affairs

Our tax governance

The VP corporate finance and controller has responsibility for tax and communicates with and advises the UK board on any significant tax matters, to ensure: • The proper control and management of tax risk; • The tax position is planned in line with the UK group’s strategic objectives. The HCA UK tax team will report material tax sensitive items to the VP corporate finance and controller who will raise these issues with the group chief financial officer where required. The group chief financial officer and the VP corporate finance and controller will determine whether to escalate any queries to the board, legal department, HM Revenue and Customs (HMRC) or any other specialist advisor.
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