Scope

Goodyear UK Limited (“the Company”) is incorporated as a limited company, registered in England and Wales, under the Companies Act 2006. This strategy applies to the Company and to the other UK companies headed by The Goodyear Tire & Rubber Company (the USA registered parent company of the worldwide group) in accordance with paragraphs 16, 19 and 22 of Schedule 19 (“the schedule”) to the Finance Act 2016. A list of the entities to which it applies is set out below at Appendix One. In this strategy, references to “‘the UK Group” are to all these entities. The strategy has been published in accordance with paragraph 16(4) of the Schedule by being included on the Group’s public website www.goodyear.co.uk. This strategy applies from the date of publication until it is superseded. References to ‘UK Taxation’ are to the taxes and duties set out in paragraph 15(1) of the Schedule which include Corporation Tax, PAYE, NIC and VAT. References to ‘tax’, ‘taxes’ or ‘taxation’ are to UK taxation and to all corresponding worldwide taxes and similar duties in respect of which the UK Group has legal responsibilities.

Aim

The UK Group is committed to full compliance with all statutory obligations and full disclosure to tax authorities. The UK Group’s tax affairs are managed in a way which takes into account the UK Group’s wider corporate reputation in line with the Group’s overall high standards of governance.

Governance in relation to UK taxation

Ultimate responsibility for the UK Group’s tax strategy and compliance rests with the Board of Goodyear UK Limited.

The Audit and Risk Committee’s requirement to monitor the integrity of the Group’s financial reporting system, internal controls and risk management framework, expressly includes those elements relating to taxation.

Day-to-day management of the UK Group’s tax affairs is delegated to the Tax Advisor, who reports directly to the Financial Controller. Each of these individuals are appropriately qualified.

The Board and Executive Directors ensure that the UK Group’s tax strategy is one of the factors considered in all investments and significant business decisions taken.

Each part of our business and each of our employees are responsible for ensuring that our Tax Strategy is complied with. This is further reviewed as part of the Senior Accounting Officer (“SAO”) reporting to HMRC by the Financial Controller to ensure the control mechanisms and procedures the Group has in place are in accordance with the Tax Strategy.

Risk Management

The UK Group operates a system of tax risk assessment and controls as a component of the overall internal control framework applicable to the UK Group’s financial reporting system.

The UK Group seeks to reduce the level of tax risk arising from its operations as far as is reasonably practicable by ensuring that reasonable care is applied in relation to all processes which could materially affect its compliance with its tax obligations.

Processes relating to different taxes are allocated to appropriate process owners, who carry out a review of activities and processes to identify key risks and mitigating controls in place.  These key risks are monitored for business and legislative changes which may impact them and changes to processes or controls are made when required.

Appropriate training is carried out for staff outside the finance team who manage or process matters which have tax implications. 

Attitude towards tax planning and level of risk

The UK Group manages risks to ensure compliance with legal requirements in a manner which ensures payment of the right amount of tax. When entering into commercial transactions, the UK Group seeks to take advantage of available tax incentives, reliefs and exemptions in line with tax legislation. The UK Group does not undertake tax planning unrelated to such commercial transactions.

The level of risk which the UK Group accepts in relation to UK taxation is consistent with its overall objective of achieving certainty in the UK Group’s tax affairs. At all times the UK Group seeks to comply fully with its regulatory and other obligations and to act in a way which upholds its reputation as a responsible corporate citizen. In relation to any specific issue or transaction, the Board is ultimately responsible for ensuring there is a mechanism in place to identify risks, including tax risks, which need to be addressed and or determining what actions should be taken to manage those risks, having regard to the materiality of the amounts and obligations in question. We, therefore consider that we have a low tax risk appetite.

Relationship with HMRC

The Group seeks to have a transparent and constructive relationship with HMRC through regular meetings and communication in respect of developments in the Group’s business, current, future and retrospective tax risks, and interpretation of the law in relation to all relevant taxes.

The Group seeks to discuss with HMRC any tax issues arising at an early stage. When submitting tax computations and returns to HMRC, the UK Group discloses all relevant facts and identifies any transactions or issues where it considers that there is potential for the tax treatment to be uncertain.

Any inadvertent errors in submissions made to HMRC are fully disclosed as soon as reasonably practicable after they are identified.

Contribution to the UK economy

As the UK Group is a significant employer in the region, the UK Group contributes to the UK economy via various indirect and direct taxes including Employer’s National Insurance contributions, the Apprenticeship Levy, Business Rates, Value Added Tax and Income Taxes that our employees pay as well as their consumer spending.

Appendix one:

Full list of companies and subsidiaries covered by this tax strategy

1.      Goodyear UK Limited

Subsidiaries:

·       Kelly-Springfield Tyre Company Limited

·       Tyre Services Great Britain Limited

·       Kettering Tyres Limited

·       Dunglaide Limited

2.      Dunlop Tyres Limited

Subsidiaries:

·       Motorway Tyres and Accessories UK Limited

·       Goodyear UK (Pension Trustees) Limited

·       Goodyear Ireland Limited (Incorporated in Ireland)

·       Goodyear Ireland (Pension Trustees) Limited (Incorporated in Ireland)

3.      Goodyear Industrial Rubber Products Limited