■Tokyo Electron Europe Limited UK tax strategy
This tax strategy covers all the UK Company of Tokyo Electron Europe Limited (“Tokyo ElectronEurope”) and explains the company’s approach to tax. Its publication follows the requirements
set out in UK Finance Act 2016 Schedule 19 and adds to them where appropriate. It applies tothe financial years ending 31 March 2024 and onwards.
The strategy covers the following four areas:
1. the approach of the UK group to risk management and governance arrangements inrelation to UK taxation
2. the attitude of the group towards tax planning (so far as affecting UK taxation)
3. the level of risk in relation to UK taxation that the group is prepared to accept
4. the approach of the group towards its dealings with HM Revenue and Customs(HMRC)

1.

Approach of the UK group to risk management and governanceTax governance within Tokyo Electron Europe works through a set of documented policies
and procedures. These describe the overall strategy and operational aspects of tax andoutline the guidelines within which this is to be managed. Adherence to these guidelines isessential.
Tax policies are set and tax risk is managed by Tokyo Electron Europe’s tax committee, which
is chaired by the VP of Finance, Europe who is a member of Tokyo Electron Europe’sexecutive committee. Material changes to Tokyo Electron Europe’s operational aspects andto tax legislation influence revisions to overall policy. It is the responsibility of Tokyo Electron
Europe tax committee to confirm to the board of directors that it has met policy standards. Inaddition, the board receives a regular report from the VP of Finance, Europe on risky tax
positions and, through a process of debate and discussion, assesses the adequacy orotherwise of positions taken. This process is critical in the overall management of the tax
affairs of Tokyo Electron Europe each year. This decision making and governance frameworkhas been outlined to HMRC and through its robust operation, HMRC consider the overall risk
rating for Tokyo Electron Europe to be low.
Tokyo Electron Europe monitor their Senior Accounting Officer (“SAO”) compliancerequirements annually to ensure that their company’s systems are fit for the purpose forreporting taxes.

2.

Attitude towards tax planning

Our UK tax policies are aligned to Tokyo Electron group’s business strategy and ethics.
Our commercial needs and business success is given highest priority and all tax planning isancillary to and undertaken in this context. We seek to be efficient in our tax affairs and in thiscontext we ensure that all tax planning is built on sound busine ss activity.
We give due consideration to Tokyo Electron Europe’s reputation and the reputation of theoverall Tokyo Electron group, our brand in the UK and overseas, corporate and social
responsibilities when considering tax planning, as well as the impact of the responsibilities
and accountabilities of officers and employees of Tokyo Electron Europe.

3.

Level of risk the group is prepared to accept

Tax management can be complex and involve a number of areas of uncertainty on which wehave to make judgements. We adopt a conservative policy in managing our tax risk. This may
include areas such as the application of law and the assessment of liabilities that are likely toarise where matters are in dispute. Where considered appropriate we make a prudent
assessment of the provision based on our policy.
We seek to manage areas of judgement by employing suitably qualified individuals in areasof strategic oversight and responsibility, with experience of managing complex matters,ensuring appropriate professional advice is obtained when relevant and having consistentpolicies (as enshrined in this tax strategy and its sister publication, the Tax Risk Managementguidelines) monitored and implemented by Tokyo Electron Europe’s tax committee and theaudit committee.
These committees consider and discuss the judgements made and apply additional levels ofassessment in the context of Tokyo Electron Europe’s risk framework.
Tokyo Electron Europe should not enter into contrived or artificial arrangements for thepurposes of avoiding tax, any transactions undertaken need to be in line with the wider
commercial strategy and growth of the group and the tax implications arising should bereviewed taking into account our relationship with stakeholders and our reputation both within
the semi -conductor industry and wider afield.

4.

Approach of the grouptowardsits dealings with tax authorities

Tokyo Electron Europe’s relationship with HMRC and in particular their CRM is based on
mutual trust, transparency and resolving issues in real time. This involves proactive
engagement with the CRM on a regular basis for them to fully understand the business andto exchange views and insights.
Our approach in dealing with HMRC is to liaise closely with regard to those significant
transactions that would have a material impact on the tax base of the company in the UK –this could be via discussions with our CRM or obtaining advance clearance from HMRC on
areas of uncertainty around the application of the legislation.
As with any large group, from time-to-time differences of opinion may arise with regard to theapplication of the UK tax legislation – where this is the case, we will seek to discuss andresolve these in an open, honest and transparent manner with HMRC.