Global Tax Strategy


Introduction

This document sets out the W.L. Gore & Associates, Inc. Group’s  (“Gore Group”) strategy and approach to conducting its tax affairs and dealing with the tax risk inherent in any international group’s business.  This document will be periodically reviewed by the Global Tax team, and any amendments will be approved by Gore Leadership as appropriate. 

The Gore Group’s Global Tax team is part of the Global Finance function which reports to the Global Finance Leader.  The Global Tax Leader leads a team of approximately 12 with specific geographic and technical responsibilities, including specialists in Transfer Pricing and Indirect Taxes.   The Gore Group’s Tax function is organised on a global basis which ensures we have consistent tax policies, strategies and processes, and can invest in the team’s continuing professional development.  Advice is sought from external advisors on material transactions and whenever the necessary expertise is not available in-house. 

The Gore Group only structures our business affairs based on sound commercial rationale and in compliance with tax regulations.  While the Gore Group may use incentives and reliefs commonly available to minimise the tax cost of conducting business, aggressive tax planning is not entertained or implemented.

UK context

The Parliament of the United Kingdom, in Finance Act 2016, implemented the requirement for certain companies, including the Gore Group, to publish an annual statement of their Tax Strategy.  This strategy statement has been published in order to satisfy this requirement.

This strategy applies from the date of publication until it is superseded and is publicly available on the Gore Group’s website.  The Gore Group’s Tax Strategy is compliant with the UK requirements laid out in part 2 of Schedule 19 FA 2016.

The following legal entities are subject to taxation in the UK and are covered by this statement:

W. L. Gore & Associates (UK) Ltd
W. L. Gore & Associates (Holding) Ltd
GGR Capital Ltd

In line with HMRC’s goal of increased cooperation between large businesses and HMRC, the Gore Group in the UK engages in early and transparent dialogue with HMRC in matters concerning tax strategy, planning, tax risks and significant transactions and is proactive in resolving issues with HMRC through open and collaborative relationships.

Compliance

The Gore Group’s dedicated tax team is guided by relevant international standards (for example OECD guidelines, including the recent BEPS initiatives) and partners with the Gore Group’s businesses to provide the necessary advice and guidance to ensure compliance with all relevant laws, regulations and reporting and disclosure requirements.  The Global Tax team ensures that all tax returns are prepared and submitted on time, and in compliance with the tax laws applicable in each country.  In doing so, they gather and retain the documentation required to answer any questions raised by local tax authorities.  The Global Tax team uses an industry standard tax compliance tracking tool to monitor the status of all local filings and related tax payments. 

All significant tax risks are identified at the time of preparation of local filings, including collecting details on all tax exposures and provisions for local and group reporting purposes.  Where such risks are identified, we engage in open and transparent conversations with the business and local tax authorities to reach an acceptable outcome.

Business partnering

The Global Tax team acts as a partner with the Gore Group’s businesses to ensure that the commercial needs of the Gore Group can be met and can be aligned with tax requirements in all locations in which we operate.  The Gore Group is clear that the importance of commercial needs should never override compliance with applicable tax laws and regulations. 

We ensure that the Global Tax team is involved in commercial decisions from planning to implementation and post-implementation review. In doing so we provide appropriate input for business proposals to ensure a clear understanding of the inherent tax consequences and local compliance requirements.  The Global Tax team also ensures accurate representation of these decisions in tax returns and statutory accounts.  Where uncertainty on significant transactions exists, the Global Tax team seeks external advice and document the decision making process.

Relationships with HMRC and other tax authorities

The Global Tax team seeks to foster professional and transparent relationships with tax authorities in all locations in which the Gore Group operate, including HMRC in the UK.  Our interaction with tax authorities is based on openness, integrity and collaboration.   We accept that due to the scale of our business there can be occasions where there will be differing legal interpretations between ourselves and the local tax authorities.  Where this occurs, we aim for early agreement on disputed matters through proactive engagement with the tax authorities in order to achieve certainty wherever possible.

The Gore Group recognises that collecting and paying tax is an important contribution to the economies and communities in which we operate.  The Gore Group uses incentives and reliefs that are acceptable to HMRC to minimise the tax cost of conducting business but does not enter into any transactions or structures lacking commercial substance or rationale which could carry reputational risk or damage our relationship with local tax authorities.