Gartner - UK Tax Strategy
Introduction
In accordance with Paragraph 16(2), Schedule 19, Finance Act 2016, Gartner sets out below its Tax
Strategy. This strategy is effective for the year ended 31 December 2023 for all UK companies within theGartner group of companies, which are indirect wholly owned subsidiaries of the US based parent,
Gartner Inc., a public traded company on the New York Stock Exchange. This strategy applies from thedate of publication until it is superseded.

This UK tax strategy is ultimately owned by the Gartner Inc CFO and the boards of the UK
companies. The tax group including the UK team of tax professionals are responsible for its day-today delivery. In its management of taxes, Gartner is guided by the following operational UK tax
principles:•Following all applicable UK laws and regulations relating to tax activities,•

Maintaining an open and honest relationship with the UK tax authorities based on full disclosureand co-operative compliance and integrity, working to secure an early agreement on items underenquiry,•

Applying diligence and care in the management of UK tax risk management processes andprocedures for all tax related activities and matters ensuring that a robust tax governanceframework is in place,•

Using incentives and reliefs to minimise the tax cost of conducting our business that are alignedwith commercial and economic activity while ensuring that these reliefs are not used for purposes
which are knowingly contradictory to the intent of the legislation.

Risk management
Managing Gartner’s UK tax affairs is a complex process across many functional areas of the businessand as such there will inevitably be risks of error or omission within those processes (tax risks) which
may result in the incorrect application of UK tax rules or calculation of UK tax returns or UK tax
reporting requirements. Consistent with Gartner’s global practices, appropriate controls of review are
in place within the context of the SOX environment to ensure compliance with the UK companies’
reporting and tax obligations, with clearly defined lines of responsibility and decisions being taken at
an appropriate level.
Through adopting such controls, the group aims to keep UK tax risk to a minimal level. However,eliminating UK tax risk entirely is impossible, therefore the Group’s attitude towards the level ofcontrol required over the processes designed to reduce these tax risks, is driven by the likelihood ofoccurrence and scale of impact of each risk. To minimise operational risks external advisors are used
for the preparation of UK tax returns/forms/disclosures, transfer pricing studies and related
documentation.
The UK tax team exercise diligent professional care and judgement to assess UK tax risks in order toarrive at well-reasoned conclusions on how the risk should be managed. An essential part of thisprocess is that the UK Tax team ensure that they are fully briefed as to tax technical developments.
Where Gartner does not have the necessary UK tax expertise in-house, or where there is uncertainty
as to the application or interpretation of UK tax law and in respect of all material tax transactions,appropriate written advice evidencing the facts, risks and conclusions is taken from third party
advisers to support the decision-making process.

In reviewing the risks of a UK tax action or decision the following would be considered:•The legal and fiduciary duties of directors and employees•The requirements of the global Gartner Inc. Code of Conduct•

The maintenance of corporate reputation,•The UK tax benefits and impact on the Gartner’s reported results•

The impact on relationships with UK tax authorities.

Resulting from this work, the Gartner Inc Audit Committee receives regular reports on themanagement of the UK tax affairs.
UK Tax planning
In analysing the possible UK tax consequences of the group’s commercial operations, Gartner willconsider a range of tax outcomes based on the underlying commercial intention of the businessactivity or transaction ensuring that we remain fully compliant with all relevant UK tax laws. The tax
function is therefore involved in commercial decision-making processes and provides appropriate
input into business proposals at an early stage, if appropriate with the support of external advisers, toensure a clear understanding of the UK tax consequences of any decisions made.
Approach toward dealings with HMRC
In dealings with HMRC and all UK Tax Authorities, Gartner and its UK tax team work to the follow
core principles:•Fully comply with all legal obligations•Undertake all dealings with HMRC in a co-operative, open, collaborative, professional and timelymanner.

•Will only seek rulings/clearances/pre-approvals from HMRC to confirm the applicable treatment
based on full disclosure of the relevant facts.

•When interpreting the UK tax laws, we will be guided by HMRC guidance notes/manuals and/orexternal advisors, to ensure the relevant law is interpreted as intended.

This UK tax strategy has been approved by the Board of Gartner UK Limited on behalf of all groupcompanies.

Date published 20 December 2023