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Legal Disclosures



The Parliament of the United Kingdom, in Finance Act 2016, has implemented a requirement that certain companies, including Aptum Technologies (UK) Limited (“Aptum”), publish annually a statement of their tax strategy. This statement is intended to meet the requirements of Schedule 19 of the Finance Act 2016.

This document, approved by the board of APTUM, sets out the APTUM strategy and approach to conducting its tax affairs and dealing with tax risk and covers only UK operations that are all managed through APTUM. The document will be reviewed periodically by the APTUM board.

The range of UK taxes that APTUM pays includes corporate income taxes, indirect taxes (VAT, land tax), employment taxes (PAYE, national insurance) and other applicable tax matters.

As a member of the Aptum Technologies group of companies (the “Group”), APTUM’s tax strategy is carried out in coordination with Group’s tax department professionals to ensure that:

The tax strategy is adopted and followed consistently throughout the Group;

The tax strategy is aligned with the Group’s overall approach to corporate governance and risk management; and

The Group and its subsidiaries pay, on a timely basis, the correct amount of tax required of them under the laws of the countries in which they operate.


As the leadership of the Group’s tax department is located in Canada, APTUM utilizes professionals from reputable international accounting firms to assist with identifying and resolving UK tax issues resulting from legislative or business changes, and for the preparation of income tax filings in the UK. The Group’s tax department consults regularly with such outside professionals to ensure that the necessary facts and circumstances have been communicated to such third parties to allow for proper resolution of issues and correct completion of returns. All tax returns are reviewed and approved by either the Group’s tax department or APTUM’s management prior to filing.


As part of the Group, APTUM is committed to conducting its tax affairs in accordance with the following objectives:

Commitment to Compliance

APTUM makes every effort to comply with UK laws, regulations, rulings, and information reporting requirements on a timely basis. This includes remittance of the correct amount of tax on a timely basis and disclosure of all relevant information to the taxing authorities.

APTUM will utilize tax incentives or opportunities to minimize the tax costs of its business but will not knowingly use such incentives and reliefs in a manner which contradicts the intent of the policy objectives of the governments which introduced the incentives or the business and operational objectives.

Attitude Concerning Tax Planning

In structuring its commercial activities APTUM will consider, among other factors, the UK tax laws with a view to value creation on a sustainable basis for its shareholders. Any tax planning undertaken will have commercial and economic substance. All tax planning activities will be conducted in accordance with the guidelines set forth in the Group’s code of ethics.

Transactions between group companies are on an arms-length basis and arm’s length transfer pricing is utilized.

Accepted Level of Tax Risk

APTUM’s on-going approach to UK tax risk management and governance is based on the principles of reasonable care and materiality. APTUM maintains on-going application of governance with strong internal controls in order to substantially reduce risk to materially acceptable levels. APTUM will ensure that the tax strategy is aligned with the Group’s overall strategy and approach to risk management, is consistent with the APTUM vision, mission, and values, and is approved by the appropriate level of management. APTUM’s appetite for tax risk is low and it only structures its affairs based on sound commercial principles and in accordance with the Group policy and relevant tax legislation. Aggressive tax planning is not proactively considered and external advice is sought where appropriate.

Approach to Dealing with HMRC

APTUM is committed to the principles of openness and transparency in its approach to dealing with HMRC. All dealings with HMRC and other relevant bodies will be conducted in a collaborative, courteous and timely manner. APTUM seeks to foster positive and professional relationships with HMRC based on honesty, integrity, transparency and collaboration.

Any inadvertent errors in submission of tax returns and tax computations to HMRC are fully disclosed as soon as reasonably practicable after they have been identified.

Risk Management and Governance

Aptum operates within the Group’s risk management framework, with comprehensive policies and procedures, which includes the management of tax risks.

Tax risks are assessed on a case by case basis, allowing APTUM to arrive at well-reasoned conclusions on how each individual risk should be managed. Where there is uncertainty in how the relevant tax law should be applied, external advice may be sought to support the APTUM’s decision making process.

Ultimate responsibility for UK tax strategy and the UK management of tax risk rests with APTUM’s board of directors, with delegated day-to-day responsibility for its tax functions performed by the Group’s tax department and APTUM management. APTUM management reports tax issues to the Group’s tax department, which in turn reports to the Group’s CFO and board of directors.