EY GDS CS
UK tax strategy
June 2022

EY values and our commitment to building a betterworking world drive our tax strategy
ScopeThis 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 year ending 1 July
2022. GDS Co-op is a Dutch-incorporated entity, which is tax
resident in the UK. A list of GDS Co-op’s subsidiaries is shownon page 3 of this strategy.
The principal activity of GDS CS is the coordination andprovision of Global Delivery Services, specifically clientrelated services in consulting, assurance, tax, strategy andtransactions services, knowledge, technology, automation,and managed services. GDS CS only provides services to EY
Member Firms and other global EY network entities and does
not provide services directly to external clients.

The Global Delivery Services
These services are coordinated by GDS Co-op’s UK subsidiary,EY 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 practiceand customs
Seeking to negotiate, where possible, Advance Pricing
Agreements (APAs) to effectively manage our risks.

This document relates only to the tax strategy of GDS
CS — not EY 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.

A better working world
The EY Network’s purpose, building a better working world,is shared by GDS CS and GDS CS is instrumental in helping toenable EY Member Firms to pursue the EY Network’s strategy
as a distinctive global professional services brand. GDS
CS’s support in building a better working world aids the EY
Network to build trust and confidence in the capital markets

EY GDS CS UK tax strategy June 2022

whilst solving some of the world’s toughest challenges toleave a lasting legacy for our people, for our clients and forour communities.
The EY Network is constantly learning through its own
purpose journey, building a better working world, and has
applied the long-term value framework to help define andmeasure its ambition, building on the EY Network’s work with
the Embankment Project for Inclusive Capitalism (EPIC) andparticipation in the development of the Stakeholder Capitalism
Metrics in collaboration with the World Economic Forum
International Business Council.
The EY Network’s performance against the Stakeholder
Capitalism Metrics in respect of FY21 can be found in its FY21
EY Value Realized report, which can be found here.
GDS CS creates long-term value by focusing on a broad setof stakeholders including employees, consumers, suppliers,communities and the UK Government, with the EY Network’s
purpose in mind, to sustain the GDS CS’s businesses for thelong term.
For GDS CS, one group of key stakeholders within ourcommunities are the tax authorities that we interact with as ataxpayer. Principally for GDS Co-op and its UK subsidiaries, thisis HMRC 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 taxpayment 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 do.

As the business environment adapts to the wide reachingchanges of the COVID-19 pandemic, maintaining the discipline
and rigour of our tested tax principles allows us to adapt andcomply with the changing tax environment.
1

The EY Network’s reputation is built by EY 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 businesses from acommercial perspective to identify andappropriately manage any tax risks
arising from them.
We seek to align our tax affairs with
their commercial and economic
substance in compliance with thetax laws of the jurisdictions in which
we operate.

Conduct

CompliantEffective risk
management
CommercialWe 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. In seeking to
be responsible taxpayers, we seek
advice from the appropriate internaland external tax professionals tomanage our risks and compliance
positions, so we can pay the righttax at the right 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 to
the Board.
Our internal tax team keeps up
to date with legislative changes
through 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 2022

2

List of subsidiaries• EY GDS (CS) Limited (UK)• EY GDS India Holding Company Limited(UK)• EY GDS US Holding Company Limited(UK)• Riverview Law Limited (UK)• EY Global Delivery Services India LLP(India)• Ernst & Young Global Talent Hub(Dalian) Limited (China)• EY GDS (CS) Philippines Inc (Philippines)• EY GDS (CS) Poland Sp. z. o. o. (Poland)• EY GDS (CS) Argentina S.R.L.
(Argentina)• Pangea3 Legal Database Systems
Private Limited (India)• EY GDS CS Mexico, S.C (Mexico)• EY GDS Mexico Holding, SA de CV(Mexico)• EY GDS (CS) Lanka Private Limited (SriLanka)• EY GDS (CS) Hungary Kft (Hungary)• EY Global Delivery Services US LLC (US)EY GDS CS UK tax strategy June 2022

3

EY | Building a better working world
EY exists to build a better working world, helping to create
long-term value for clients, people and society and build
trust in the capital markets.
Enabled by data and technology, diverse EY teams in over
150 countries provide trust through assurance and help
clients grow, transform and operate.
Working across assurance, consulting, law, strategy, tax andtransactions, EY teams ask better questions to find new
answers for the complex issues facing our world today.
EY refers to the global organization, and may refer to one or more, ofthe member firms of Ernst & Young Global Limited, each of which isa separate legal entity. Ernst & Young Global Limited, a UK company
limited by guarantee, does not provide services to clients. Information
about how EY collects and uses personal data and a description of therights individuals have under data protection legislation are available
via ey.com/privacy. EY member firms do not practice law whereprohibited by local laws. For more information about our organization,please visit ey.com.
© 2022 EYGM Limited.
All Rights Reserved.
EYG no. 005829-22Gbl
UKC-0229791.indd (UK) 05/22
Artwork by Creative UK.
ED None
In line with EY’s commitment to minimise its impact on the environment, this document
has been printed on paper with a high recycled content.

This material has been prepared for general informational purposes
only and is not intended to be relied upon as accounting, tax or otherprofessional advice. Please refer to your advisors for specific advice.

ey.com