Treasure Data UK Limited
Tax Strategy

This UK tax strategy applies to Treasure Data UK Limited (“TDUK”) and has been updated for the financial year ending 31 March 2026.

We publish this tax strategy in compliance with the UK Subsidiaries’ obligations under paragraph 19(2) and 22(2) of Schedule 19 of the Finance Act 2016. This policy has been reviewed and approved by TDUKs Senior Accounting Officer (SAO) and Head of Tax, and presented to the Board of Directors, in the financial year ending 31 March 2026, for their approval.

Scope

Our tax strategy applies to all taxes relevant to TDUK, including:

UK Corporation Tax
VAT
Payroll Taxes
R&D Tax Relief Incentives
Transfer Pricing and Withholding Taxes
Any other taxes arising in the jurisdictions in which we operate

This strategy applies to all employees, officers, and third‑party advisers engaged in tax‑related activities.

Our Approach to Tax Risk Management and Governance

TDUK is committed to maintaining strong and effective tax governance. We adhere to the requirements of Finance Act 2009 Schedule 46, ensuring that appropriate tax accounting arrangements are in place and overseen by our designated SAO.

Our governance principles include:

Board Oversight: The Board maintains ultimate responsibility for the tax strategy and receives regular updates from the appointed SAO and the Head of Tax.
SAO Responsibilities: The appointed SAO ensures that robust systems, controls, and processes are in place to manage tax compliance across TDUK. The SAO conducts regular risk assessments using a documented methodology that considers:
- Complexity of tax positions
- Materiality threshold (quantitative and qualitative)
- Changes in tax legislation
- HMRC guidance and interpretation
- Business operational changes
Documented Controls: All material tax processes including corporate tax, VAT, employment taxes, transfer pricing, and R&D claims are documented, monitored, and reviewed at least annually.
People: An important component of our tax risk management is ensuring all relevant personnel receive ongoing training to understand tax obligations, operational tax processes, and compliance expectations.
In addition, TDUK works with reputable professional firms to ensure that the company complies with its legal and regulatory obligations in relation to tax filings, reporting, and payments.
Processes and Technology: We ensure that we have appropriate processes and technology in place to help us manage tax risk:
- Tax Compliance Systems: Use of global compliance monitoring systems and financial management tools.
- Four Eyes Review: A standardised “four eyes” review process for tax returns, payments of taxes and reported tax positions.
- Segregation of Duties: Treasury, legal and accounts payable processes to support the tax function but that operate separate approval processes and appropriate separation of duties.
- Training Programs: Awareness training for relevant non-tax stakeholders.
External Expertise: Regular communication with external tax specialists to supplement our internal expertise when appropriate.

Attitude To Tax Planning

Our approach to tax planning is principled and aligned with commercial and economic reality and we do not engage in artificial or aggressive tax arrangements. We endeavour to:

Ensure that our global tax position reflects genuine commercial activities.
Apply double tax treaties and available tax incentives (including R&D tax reliefs) as intended by legislation.
Ensure that all intra‑group pricing complies with the latest OECD Transfer Pricing Guidelines and is supported by appropriate documentation.

Tax Compliance and Reporting

TDUK is committed to:

Filing accurate, complete, and timely tax returns in all jurisdictions.
Paying the correct amount of tax at the correct time.
Maintaining transparent documentation supporting tax positions, adjustments, and elections.
Applying consistent accounting policies across all Treasure Data group entities to ensure reliability of tax‑sensitive financial information.

Working with HMRC