Oxford Instruments plc – Tax Strategy
Introduction
Oxford Instruments’ (the “Group”) tax strategy supports the strategic objectives of theGroup and applies equally to both UK and non-UK taxes and to all forms of tax. TheGroup pays a significant amount of tax to national and local governments, including
taxes on employment, corporate taxes on profits, customs and excise duty on purchases,
withholding taxes and environmental taxes. We also administer VAT and similar sales
taxes charged to our customers and withholdings on payments made to our employees.

Objectives
Oxford Instruments plc manages its tax affairs in accordance with the following
objectives:•Ensuring compliance with all relevant tax law in all jurisdictions in which theGroup operates whilst managing the associated tax costs in a manner that is consistent
with the Group’s Code of Conduct and Ethics policy (as published on our website) and
its attitude to commercial risk.
•Seeking to maintain stable effective and cash tax rates which reflect thegeographic markets in which we operate and the Group’s tax attributes such as
brought forward losses and special deductions such as for research and development.
•Ensuring that all communication with tax authorities is conducted in atransparent and professional manner.

Risk management and governanceOxford Instruments’ tax strategy is reviewed on an annual basis by the Audit and Risk
Committee, who receive updates on tax matters from the Group Finance department atleast once per year and more often if required. In addition the Audit and Risk
Committee review the Group’s risk register quarterly and where appropriate this would
include tax risks.
The Group identifies tax risks on a jurisdictional basis. In some jurisdictions the Group
employs suitably qualified tax specialists who work closely with operating businesses toensure tax risks are identified and suitably managed. In other jurisdictions the Groupworks closely with external advisers to ensure tax risks are identified and suitablymanaged. The Group has a clear delegation of authority which requires transactions
outside the ordinary course of business or with unusual tax consequences to be referredto the Group Finance department who will decide the best course of action andescalate to the Board if felt appropriate. The Group has a clear policy on the UK’s
Corporate Criminal Offence of failure to prevent the facilitation of tax evasion.

It is acknowledged that the global taxation landscape is complex and constantly
evolving. To reflect this we actively monitor, with the assistance of professional
advisors, local and international developments, and aim to manage the tax costs andtax risks associated with all commercial transactions in the same way as for othercommercial costs. This includes considering how changes in tax legislation in the UKand overseas will impact on our effective and cash tax rates.

Attitude to tax planning
We actively manage our liabilities across all taxes in the UK and overseas, in a mannerthat is consistent with our brand, our corporate and social responsibilities, and whichreflects the commercial operations of our business. We seek to ensure that we pay theright amount of tax at the right time based on the laws, rules and regulations of theterritories where we operate.
Innovation is central to our business and we seek to claim tax incentives for researchand development and the utilisation of patent box regimes for intellectual property.
We involve our technical specialists in the preparation of such claims to ensure that theamounts claimed are just and reasonable. External advisers would also be consulted toensure our approach to preparing claims is in line with legislation.
We will not enter into tax planning, transactions or structures that are notifiable to tax
authorities under mandatory tax avoidance disclosure regimes.
Our business comprises a number of business units which are autonomously managed.
We operate a transfer pricing policy which reflects this and all transfers of goods andservices between related companies are conducted on an arm’s length basis.

Acceptable levels of tax risk
Oxford Instruments recognises that tax laws are complex and may be subject todifferent interpretation. As a consequence, tax positions may be reviewed andchallenged by revenue authorities from time to time. We seek to mitigate this risk by
taking appropriate professional advice and by fostering good working relationships
with tax authorities.
The Group has no rigid level of acceptable tax risk. When assessing a particular tax risk
the Group considers various factors including reputational, financial and operationalrisks, as well as any potential impact on our relationship with any tax authorities.
When appropriate this assessment will be informed by discussions with tax advisers.

Dealings with tax authorities
In our approach to dealing with tax authorities (including HMRC):•

We act in a professional and courteous manner at all times;•We seek an open and transparent relationship based on trust;•We aim to respond to all enquiries in a timely fashion; and•We seek to resolve any disagreements amicably by discussion wherever possible

Where a particular transaction requires an advance clearance from a tax authority wewould not normally proceed with such a transaction unless that clearance is obtained.
Where the Group considers that risk or uncertainty could exist, for example due to achange in the law, and the relevant tax authority offers the possibility of early
engagement we will actively engage in dialogue on a real-time or pre-filing basis
where it is practical to do so.
Subject to available resources we will participate in consultation on future tax law
change where we believe that it is in the Group’s best interests to do so.
Oxford Instruments plc regards publication of this document as satisfying its duty to comply withParagraph 16(2), Schedule 19 of the UK Finance Act 2016 in respect of the year ending 31 March 2024.