EY GDS CS
UK tax strategy
June 2019

EY values and our commitment to building a betterworking world drive our tax strategy
ScopeA better working world

This tax strategy applies to EY GDS Holdings
Coöperatief U.A. (‘GDS Co-op’) and all its wholly
owned corporate subsidiaries, collectively ‘GDS CS’,for the financial years ended 29 June 2018 and28 June 2019. GDS Co-op is a Dutch-incorporated
entity, which is tax resident in the UK. A list of GDS
Co-op’s subsidiaries is shown on the back page ofthis strategy.

GDS CS’s purpose, Building a better working world, isfundamental to its strategy as a distinctive global professional
services brand. It helps build trust and confidence in thecapital markets whilst solving some of the world’s toughest
challenges to leave a lasting legacy for our people, for ourclients and for our communities.

The principal activity of GDS CS is the coordination andprovision of Global Delivery Services — Client Services,
specifically client-related services in Advisory, Assurance,Tax, Transaction Advisory, Knowledge and Automations, toMember Firms of the EY network (‘Member Firms’) and other
EY network entities. GDS CS only provides services to MemberFirms and other EY network entities and does not provide
services directly to external clients.

The Global Delivery Services
Client Services are coordinated by GDS Co-op’s UK subsidiaryEY GDS (CS) Limited and provided by GDS Co-op’s otheroperating subsidiaries. GDS CS provides its services on alimited-risk basis.
The GDS CS entities pay tax in their jurisdiction of tax
residence, which is primarily outside the UK. Whilst thisstrategy relates to GDS CS’ UK activities only we apply thesame principles in relation to non-UK taxes. In particular:•Working closely with tax authorities in a cooperative
manner where possible based on local practice andcustoms•

Seeking to negotiate, where possible, Advance Pricing
Agreements (‘APAs’) to effectively manage our risks

For GDS CS, one group of key stakeholders within ourcommunities are the tax authorities that we interact withglobally as a taxpayer. Principally for GDS Co-op, EY GDS (CS)
Limited and EY GDS India Holding Company Limited, this isHMRC in the UK with whom we seek to maintain a positive
and transparent relationship. We welcome the opportunity to
publicly outline our tax strategy as a business.

Our tax principles
Our objective is to pay the right amount of tax at the righttime to meet our statutory obligations. We seek clarity andcertainty on tax matters wherever feasible. When dealing withthe tax affairs of GDS CS, we focus on:•

Being on time and in compliance with our tax filing and tax
payment obligations•

Effectively managing our risks•Working closely with HMRC in a cooperative manner on areal time basis•

Maintaining a tax strategy which is fully supported andowned by the Board of GDS Co-op•

Aligning our tax affairs to commercial activity of theservices we provide•

Demonstrating EY values at the heart of everything we doThis document relates only to the tax strategy of GDS
CS — not Member Firms, who are responsible for their own
tax strategies.
GDS Co-op and EY GDS (CS) Limited publishes this document
in satisfaction of their duties under paragraphs 22 (2) and19 (2) of Schedule 19 of Finance Act 2016.

EY GDS CS UK tax strategy June 20191

Our reputation is built by our people acting
according to the EY values
Governance and conduct
Our tax strategy is approved and owned by the Board of GDS Co-op.
Our internal tax team has a clear accountability up to the Board for themanagement of tax arising from our business operations.
Our internal tax team has a clear mandate from the Board to act in a wayaligned to EY values, which define who we are:•People who demonstrate integrity, respect and teaming.

•People with energy, enthusiasm and the courage to lead.

•People who build relationships based on doing the right thing.

The Board’s mandate is for GDS Co-op to behave in accordance with the low risk
characteristics as set out in HMRC’s Business Risk Review process.

Commercial attitude totax planning
We undertake transactions which
are commercially driven and do not
put in place artificial or contrived
arrangements that could give rise to
reputational damage for GDS CS.
We structure our business operations
from a commercial perspective toidentify and appropriately manage any
tax risks arising from them.

Conduct

CompliantEffective risk
management
Commercial

Our tax affairs are aligned inaccordance with their commercial andeconomic substance in compliancewith the tax laws of the jurisdictions inwhich we operate.
We claim tax reliefs as aligned to thetax laws under which we operate.

Cooperative

Compliance andeffective risk
management
Compliance is at the heart of what
we do, and we focus on staying
compliant with our tax filing and tax
payment obligations.
GDS CS’s business is of a significant
scale, and we deal with a large
volume of complexity in the tax
systems in the jurisdictions inwhich we operate. As responsible
taxpayers, we seek advice from theappropriate internal and external
tax professionals to manage ourrisks and compliance positions so
we can pay the right tax at theright time.
We have clearly documented
processes and controls relating
to the management of our tax
compliance processes.
Our internal tax team has clear roles
defined by their areas of process
and tax experience. They report to a
Head of Tax who, in turn, reports tothe CFO and the Board.
Our internal tax team keeps up
to date with legislative changesthrough training and continuing
professional development.

Cooperative approach with HMRCGDS CS maintains an open and honest dialogue with HMRC,
and we do so on a timely basis.

We communicate our positions based on full disclosure of
the relevant facts and legislative position.

We meet and correspond with HMRC regularly throughout
the year and keep abreast of tax developments.

Where we have uncertainty in how the underlying legislation
applies, we seek to resolve the matter through an open andhonest dialogue.

We keep HMRC informed of significant transactions andbusiness changes, and disclose and discuss areas ofsignificant uncertainty in how the legislation applies.

EY GDS CS UK tax strategy June 20192

List of subsidiaries• EY GDS (CS) Limited (UK)• EY GDS India Holding Company
Limited (UK)• EY Global Delivery Services India LLP(India)• Ernst & Young Global Talent Hub(Dalian) Limited (China)• EYA GTH Manila Inc (Philippines)• EY GDS (CS) Poland Sp z o o (Poland)• EY GDS (CS) Argentina S.R.L.
(Argentina)

EY GDS CS UK tax strategy June 20193

EY | Assurance | Tax | Transactions | Advisory
About EY
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EYG No. 003109-19Gbl
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This material has been prepared for general informational purposes only and is not intended tobe relied upon as accounting, tax or other professional advice. Please refer to your advisors for
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