Tax policy

• shelter profits in tax havens or low tax countries where the group does not have a legitimate commercial presence;
• use licensing arrangements or any other scheme to transfer artificial profits to low tax countries; or
• subscribe to or participate in schemes that provide no commercial benefit to the group, or where tax benefit is a significant contributing factor.

The group justifiably mitigates its tax liabilities and compliance costs by making reasonable and appropriate use of the legislative framework and the available options in each territory within which it operates. As such, the group engages in legitimate tax planning in order to make the most efficient use of permitted tax reliefs and other incentives as well as access tax losses from prior periods. Where possible, the use of such arrangements will be presented to and agreed with the appropriate tax authority. Where this is not possible, the group seeks expert advice to confirm that if there were to be challenges to its position these would more likely than not be settled in its favour.

The Tax department employs tax specialists based in Paris, New York, London and Berlin. The Head of the Tax department reports to the Group General Counsel.

The group is committed to establishing and maintaining a constructive and transparent relationship with the tax authorities in all countries in which it operates and where such relationships are permitted under local legislation and customs. The group considers that such arrangements provide long-term benefits for both the group and the local tax authorities.

>> Vivendi Group UK Tax Policy 2023