GENTING UK - APPROACH TO TAXATION

1. Overview and Scope

As one of the UK’s largest leisure and entertainment businesses, provided through its 42 land based UK casinos and online gaming and betting platforms, which employs over 4,500 staff, Genting UK makes a significant contribution towards UK tax revenue.

Genting UK recognises that it is important for it to ensure that effective tax standards are maintained throughout its UK operations which are consistent with its core values and reflect the strong governance which is required through having a UK plc, and operating within the highly regulated gambling environment.

This is an outline of the framework and overriding policies within which the UK Group manages its tax operations, as required by Schedule 19 to the Finance Act 2016. The strategy covers the financial year ended 31 December 2017, and will be reviewed annually and updated as deemed necessary. The Tax Strategy covers all tax, UK National Insurance and UK Excise Duty liabilities of the UK Group’s operations, whether in the UK or overseas.

2. Policy Oversight and Governance

The Tax Strategy and accompanying policies and procedures are owned by the Board of Genting International Investment (UK) Limited (‘the Board’). The Board has delegated the overall responsibility for the UK Group’s implementation and upholding of the Tax Strategy to the Genting UK Chief Financial Officer (‘UK CFO’) – the person with overall responsibility for Genting UK’s financial accounting arrangements, and the UK Group’s Senior Accounting Officer.

The day to day management of the UK Group’s tax affairs are delegated further by the UK CFO to the UK Group’s tax function – a team of internal staff appropriately trained and qualified with recognised professional bodies (which set additional requirements for professional standards and integrity). Part of the success of the tax function will be measured against achieving the aims within this Tax Strategy, and significant deficiencies are reportable to the Audit Committee and the Board.

The Tax Strategy is disseminated to primary stakeholders who have an important role in upholding its principles, and is available on the UK Group’s intranet.

3. Tax Planning

The UK Group takes the obligations set out within any relevant law, rule or regulation which affects taxation seriously. In particular, it does not participate in marketed or notifiable avoidance schemes, and will only look to enter into business arrangements which are commercially driven; comply fully with the word of, and the understood intentions of, current tax laws; and are unlikely to be considered contrived, artificial or aggressive by HMRC, the wider tax community, and the public.

The UK Group also has a responsibility to its shareholder to maximise its profitability, and so will seek to structure commercially motivated arrangements in a tax efficient manner, within the constraints set out in this Tax Strategy. In its simplest sense, this may involve taking advantage of tax incentives, reliefs or exemptions offered by law.

4. Risk Management and Third Party Advice

The majority of the transactions which the UK Group undertakes have a clear tax treatment. However the subjectivity, complexity and sheer volume of tax legislation makes it practically impossible for Genting UK to proceed with zero risk of incorrect tax treatment in everything it does.

The UK taxes and duties the UK Group pays are “self-assessed” - it is not HMRC’s role to review all business transactions. Genting UK uses the experienced internal and external resources available to it to form its own conclusions wherever possible. Those conclusions are reached within the controls set out in this Tax Strategy.

There is no pre-defined level of materiality or risk, at which point advice will be sought or disclosure made. The risks associated with tax positions are considered on a case-by-case basis. The UK Group may, from time to time, use tax experts within experienced professional practice if the complexity, risk, materiality, and also the cost of effective risk mitigation deem it appropriate. Genting UK will also disclose to HMRC where it does not believe it has robust support for a self-assessed tax filing position.

Genting UK’s compliance with the requirements of the Senior Accounting Officer regime, in order to be in a position to annually declare that its tax accounting arrangements were appropriate, together with ongoing Internal Audit function review of areas affecting taxation, and the Continual Professional Development of its Tax Function, also contribute towards effective tax risk management.

5. HMRC collaboration

The UK Group continually seeks to maintain regular communication with HMRC, and work collaboratively in an open and honest way to ensure that the right tax is paid at the right time, minimise uncertainty, and reduce the risk of future disputes. The Genting UK tax function and its designated HMRC Customer Relationship Manager have a verbal conversation at least on a monthly basis.

The UK Group has willingly and transparently participated in any assurance reviews, and been open to assist in surveys and studies, which HMRC have undertaken on various taxes in recent years, and it will continue to do so.

On occasion, the views of Genting UK formed within the framework of this tax strategy may differ from those of HMRC. In this event, the UK Group will still work with HMRC to explore all available avenues, in order to reach a suitable conclusion.

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