This document has been prepared to meet the requirements set out in the UK FinanceAct 2016, Schedule 19, para 16(2) in respect of the duty of Universal Music Group(‘UMG’) UK subsidiaries to publish a UK Tax Policy for the year ended 31 December
2023, either on their own website or in a freely available document. Many of UMG’ssubsidiaries do not have a suitable UK website and so this document is publishedcentrally by UMG to comply with the above legal requirement.
The Group Tax Policy is reviewed annually and has been approved by UMG and applies
to all entities in the UK which are members of the UMG. The following sub group andcompanies are required to disclose their Tax Policy:▪
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Universal Music Holdings Limited and its subsidiaries
My Way Productions Limited

The UMG’s Tax Policy aims to ensure that:
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the Group’s attitude towards tax is clearly understood at all levels;
appropriate structures are identified and implemented so that taxes areproperly calculated and paid in the relevant territories within the prescribedtime frames;
appropriate accounting policies (including transfer pricing policies) are identified
and followed so that taxes are properly calculated and paid in the relevant
territories;
tax reliefs which are rightfully available to the Group are identified and claimed
when appropriate;
external advisers engaged by the Group have the requisite qualifications andreputation;
open and constructive relationships with local tax authorities are developed andmaintained wherever possible and permitted by local law; andin the event that any company or part of the Group is subjected to a tax audit,
the appropriate staff and/or external advisers are assigned to the matter so as
to ensure the proper conduct of the audit process and its conclusion as quickly
as possible.

The policy applies to all types of taxes at every jurisdiction level (local, regional andnational).
The Group has very low tolerance to tax risk and notably does not:▪

shelter profits in tax havens or low tax countries where the Group does nothave a legitimate commercial presence;▪
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use licensing arrangements or any other scheme to transfer artificial profits tolow tax countries; orsubscribe to or participate in schemes that provide no commercial benefit tothe Group, or where tax benefit is a significant contributing factor.

The Group justifiably mitigates its tax liabilities and compliance costs by making
reasonable and appropriate use of the legislative framework and the available options
in each territory within which it operates. As such, the Group engages in legitimate tax
planning in order to make the most efficient use of permitted tax reliefs and otherincentives as well as access tax losses from prior periods.

Where possible, the use of such arrangements will be presented to and agreed withthe appropriate tax authority. Where this is not possible, the Group seeks expert
advice to confirm that if there were to be challenges to its position these would more
likely than not be settled in its favour.
The Tax department employs tax specialists based in Hilversum, Santa Monica, NewYork, London and Berlin. The Head of the Tax department reports to the EVP, ChiefFinancial Officer and President of Operations.
The Group is committed to establishing and maintaining a constructive andtransparent relationship with the tax authorities in all countries in which it operates
and where such relationships are permitted under local legislation and customs. The
Group considers that such arrangements provide long-term benefits for both theGroup and the local tax authorities.