Tax Strategy

C.N. Unwin Ltd Tax Strategy – October 2018

SECTION 1: INTRODUCTION

1.1 Background
CN Unwin Ltd, “Unwin” is a market leader in delivering complete wheelchair safety solutions, maximizing accessibility for all. Unwin is located in Martock and the group is ultimately owned and controlled by Investor AB, a Swedish listed company holding stakes in a diverse range of businesses.

The immediate parent of Unwin is BraunAbility, a US manufacturer/provider of wheelchair accessible vehicles, lifts, and mobility solutions.

This document sets out the strategic tax objectives of Unwin and satisfies the UK’s requirement to publish its tax strategy under Schedule 19 of the Finance Act 2016.

1.2 Ownership and approval
The Tax Strategy is approved by the Board of Directors of Unwin

Unwin management is responsible for leading the Tax Strategy, assisted by licensed third party tax advisers.

The Tax Strategy will be periodically reviewed, and any amendments will be approved by the Board of Directors.

1.3 Scope
Unwin is exposed to a wide range of taxes, including corporation tax, VAT, insurance premium tax and national insurance contributions. In addition, Unwin has around 65 employees, generating a substantial further tax contribution to the economy through PAYE and NIC

SECTION 2: TAX STRATEGY

2.1 Summary
Unwin is committed to paying the correct amount of tax required under the laws and regulations of UK tax legislation and practice. Unwin takes a conservative approach to tax planning and does not pursue aggressive tax planning arrangements.

Unwin uses third party advisers to provide advice and guidance to help assess the tax risks and ensure its compliance with applicable laws, rules, regulations and disclosure requirements.

2.2 Risk Management
It is the policy of the Unwin to ensure that all tax positions taken are consistent with the core values of the company, which notably include respect for the environment and respect for people and communities. The policy ensures that the Unwin pays the appropriate amount of tax in relation to its commercial activities.

The main tax risks for the Unwin are identified as:
2.2.1 Tax compliance and reporting risks. These risks are associated with the failure to comply with the tax regulations of the appropriate authorities within each market that Unwin operates. The risk is reduced by using external professional advisers to prepare, advise and review tax computations and submissions.

2.2.2 Transactional risks. As Unwin operates across several markets with associated complex tax issues, advice is always taken from professional advisers when new distribution channels are established, or current transactions amended, in order to ensure adherence to the correct rates and treatment of tax.

2.2.3 Reputational risks. Unwin ensures they are open and transparent with every governing entity in every market, although it will be primarily with the HMRC in the UK. Unwin has a conservative approach to tax planning and aims to have open communications with all tax authorities.

2.3 Documented Policies and Procedures.
Unwin will comply with documented policies and procedures in relation to tax risk management and will conduct risk assessments before entering any new initiatives. Where appropriate, this will include obtaining external professional opinions to verify and support the Unwin management team’s conclusions.

2.4 Tax Planning
The Unwin strives to maintain a low risk rating with HMRC.

Whilst seeking to be efficient in the tax affairs and reduce the tax liability through taking of reliefs and incentives where applicable, the Unwin ensures that any tax planning is based on sound commercial principles but will show respect at all times for the intention and spirit of the law, as well as the letter of the law.

2.5 Relationship with HMRC and other tax authorities
The Unwin seeks to build and sustain honest, transparent relationships with HMRC and other tax authorities that are constructive and based on mutual respect, avoiding unnecessary delays and disputes wherever possible.

SECTION 3: GOVERNANCE

3.1 Internal ownership and structure
The BraunAbility management team implements the world-wide group tax strategy with respect to the BraunAbility group holdings, which includes Unwin and its UK tax strategy. Additionally, the BraunAbility management team reports to and consults with the Investor AB group on all material tax strategies and risks within the group.

3.2 External Consultants
For matters where the Unwin management team consider they have insufficient skill or experience, external expert consultants who have suitable knowledge of Unwin and the greater BraunAbilty group, the industry, and tax law, are engaged to provide advice and guidance.

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