Global Tax Policy of Shinsei Bank Group

Shinsei Bank Group is a large Japan headquartered financial services organization with operations mainly in Japan. As one of our management principles we, Shinsei Bank Group, strive for highly transparent management and values and aim to act in the interest of our stakeholders and be trusted by all of them in pursuit of our local and international business. To realize this goal, we have enacted The Charter of Shinsei Bank Group Corporate Behavior and The Shinsei Bank Group Code of Conduct. In full alignment with our management principles, we recognize that tax payments are an important part of our social responsibilities and our public role. In order to enhance the achievement of this responsibility and public role, we set out our Global Tax Policy hereafter.

1. Compliance and fair tax payments

We pay our taxes in a timely and appropriate manner in accordance with all applicable laws, including without limitation local and international tax laws, tax treaties and OECD guidelines, following an interpretation compliant with the spirit and purpose thereof. We complete all statutory procedures, including filing of tax returns and tax payments, within the applicable deadlines.

2. Tax governance

Our Chief Officer for Group Corporate Planning and Finance heads our tax governance framework and allocates appropriate authority to the tax team members of our headquarters’ Group Financial and Regulatory Accounting Division. These tax team members collect tax related information and data of our group companies and manage the group tax compliance based on our internal rules. Evaluation of the tax risk and determination of the tax position accompanying it are considered by the tax team members of our Group Financial and Regulatory Accounting Division and decisions are only made by personnel who are granted the appropriate authority based on our internal rules. Such decisions are reported to the directors and the audit and supervisory board members as necessary.

3. Tax planning

We emphasize that our decisions related to business planning and/or business operation are made based on commercial purposes. We recognize tax is cost and therefore we consider to optimize our tax position. We, however, do not conduct any artificial transactions or unethical transactions aimed at tax avoidance. We will act on best efforts to carry out all internal transactions in line with the arms-length principle and we do not operate our businesses in perceived Tax Havens for the purpose of artificial tax avoidance.

4. Treatment of uncertain tax positions

We recognize that we may face uncertain tax positions arising from uncertain interpretation of tax laws and relevant rules. In such case, we, generally, take a most appropriate position. A most appropriate means a position that can be regarded as rational position on the basis of a reasonable interpretation. If the materiality of such uncertain tax position is regarded as significant and/or such uncertain tax position may have a significant impact to the amount of our tax payments and/or our financial statements, we will endeavor to minimize such uncertainty by obtaining the opinion of external tax advisors, and/or seeking for an advance ruling with the tax authorities.

5. Relationship with tax authorities

We endeavor to establish good relationships with the tax authorities by disclosing all relevant information in a timely and appropriate manner under the limitation of our responsibility for protecting and managing proprietary information in accordance with all relevant laws without limitation to tax laws. If we face a conflict in interpretation of tax laws with the tax authorities, we aim to settle this by explanation of the most appropriate position based on available decrees, precedent case, etc.

This Global Tax Policy was approved by Board of Directors of Shinsei Bank on March 22, 2018.

Footnote:
Publication of this document is regarding as complying with statutory requirements in the jurisdictions in which we operate to publish a tax strategy, including in the UK in accordance with Para 16(2), Schedule 19 FA2016.