UK ACCO Brands Tax Strategy

Introduction

This Tax Strategy is published in respect of financial year ended 31 December 2022, in accordance with Paragraph 16(2) of Schedule 19 of the United Kingdom Finance Act 2016.

This Tax Strategy applies to ACCO Brands Europe Ltd and its UK subsidiaries (the “UK Group”). It has been endorsed by the Vice President of Global Tax and the Vice President Finance, Europe, and has been approved by the Board of Directors of ACCO Brands Europe Ltd.

This Tax Strategy will be reviewed annually.

Overview of the Group

ACCO Brands Corporation (NYSE: ACCO) is the ultimate parent company of a multinational group of companies and partnerships (“ACCO Brands”) including ACCO Brands Europe Ltd. ACCO Brands designs, manufactures and markets consumer and end-user products that help people work, learn, play and thrive. Its widely recognized brands include Five Star^®, GBC^®, Hilroy^®, Kensington^®, Leitz^®, Mead^®, NOBO^®, Rapid^®, Rexel^®, PowerA^® and many more.

Product lines include staplers, punches, paper shredders, binding machines, laminators, notice boards and easels, stationery products, computer accessories, DIY tools, coloured pencils, and console gaming accessories and more. ACCO Brands’ markets a wide portfolio of products in more than 100 countries across the globe, through its extensive logistics, distribution, and sales networks.

Aim

ACCO Brands is committed to full compliance with tax laws and practice, statutory obligations, internationally recognised standards and to providing full disclosure to tax authorities. The UK Group’s tax affairs are managed in a way which considers ACCO Brands’ wider corporate reputation in line with ACCO Brands’ overall high standards of governance, core ethical behaviours and values.

Governance in relation to taxation

The Executive Leadership Team (“ELT”) is ultimately responsible for corporate governance, with the Chief Finance Officer (“CFO”) having responsibility for financial governance.
The ELT is responsible for ensuring there is an appropriate framework for the implementation of the policy and oversight of the identification and management of tax risk. The ELT maintains responsibility for evaluation of controls and implementing new controls where material tax risks are identified.
The ELT has delegated responsibility for tax governance to the Vice President of Global Tax, who reports to the CFO, as required.
The Finance Senior Leadership Team (“FSLT”) meets regularly, and consists of the CFO, Vice President of Global Tax, the two lead European Finance employees (Senior Vice President of Finance and Vice President of Finance, Europe), as well as other international Finance colleagues. These meetings are an opportunity for any material tax issues to be discussed.
Local directors and financial controllers of each legal entity are responsible for ensuring that all applicable regulations, as well as internal guidelines and compliance procedures relating to taxation, are observed.
Application of the Tax Strategy within EMEA is managed on a day-to-day basis by an in-house team of suitably qualified professionals, led by the Director of EMEA Taxation. Regular communication is maintained with the Vice President of Global Tax, senior European Finance, and the local Finance teams involved in compliance and reporting processes.
Review and approval of tax computations is conducted by the EMEA tax team and the Vice President of Finance, Europe.
Certain taxes are managed outside of the EMEA tax team, such as PAYE and VAT, which remain under the oversight of the Vice President Finance, Europe.

Tax Department

The Tax department’s objectives are to support the UK Group’s strategy while ensuring compliance with relevant laws and filing obligations.

Tax department objectives are as follows:

To have a clearly understood, communicated, and supported strategy
Paying the appropriate amount of tax by the due dates
Forecasting and planning tax cash payments accurately
Ensuring that tax returns are submitted on time and that the most effective tax elections, claims and options are considered to manage the tax paid by the UK Group, but will not use them for purposes which are knowingly inconsistent with the intent of the legislation
Ensuring that any transactions undertaken by the UK Group are effected tax efficiently
Implementing and maintaining controls and procedures, relating to all taxes, ensuring that the correct amount of tax is calculated
Act in a proactive and responsible fashion in relation to the UK Group’s tax affairs; and
To maintain the UK Group’s reputation as a fair contributor to the worldwide economy, which applies tax rules in good faith and in the spirit, they are intended

Risk Management

ACCO Brands operates a system of tax risk assessment and controls as a component of the overall internal control framework.
Potential tax risks are assessed, and processes and controls are implemented to mitigate the risks to an acceptable low level.
Internal control procedures and processes are subject to regular reviews, internal audits and self-assessment programs.
Advice is sought from external advisers where appropriate.

Attitude to Tax Planning

Ensuring we pay the right amount of tax at the right time is a core objective of the ACCO Brands Tax department. We will manage our tax costs through maximising the tax efficiency of our business transactions; utilising available tax incentives, reliefs and exemptions in line with the spirit and intent of tax legislation.

We recognise that there is sometimes more than one tax outcome in commercially motivated transactions. We will not, however, wilfully engage in tax schemes, abusive tax havens, or structure transactions in such a way that we believe are artificial and/or contrary to the spirit and the clear intentions of the tax legislation concerned.

We will only use tax planning to support the business strategy. As such, all decisions will have a sound commercial rationale, will be within the confines of the law and will take into account any impact that such actions will have on our external reputation.

Appropriate external advice, including Tax Counsel opinions where relevant, will be sought on matters of significant complexity or uncertainty, or on matters where there is insufficient in-house expertise.

HMRC Relationship

The UK Group is committed to an open, transparent relationship in its dealing with HMRC and will seek to work in partnership with HMRC.
The UK group will ensure HMRC are kept aware of significant transactions and changes in the business and seek to discuss any tax issues at an early stage. Where appropriate advance clearance will be sought.
When submitting tax computations and returns, the UK Group discloses all relevant facts and identifies any transactions or issues where it considers there is potential uncertainty regarding the tax treatment.
Any inadvertent errors in submissions made to HMRC are fully disclosed as soon as reasonably practicable after they are identified.
All dealings with the HMRC and other relevant bodies will be conducted in a collaborative, courteous and timely manner.

Issued: December 2022
Version: 2022/1
Next review due: December 2023