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This tax strategy is published in accordance with paragraph 16(2), Schedule 19 of Finance Act 2016 and applies in respect of the following group companies:
This strategy document applies for the year ended 31 March, 2019 and will be reviewed and updated annually. As part of a multinational group we are aligned with and follow wider Virtusa's guiding principles, code of conduct and will be open and tax policy for the group. This strategy applies from the date of publication until it is superseded. References to "UK taxation" are to the taxes and duties in the UK which include:
Tax Risk management
Ultimately the board of directors of the group companies are responsible for the tax affairs of the two companies. This responsibility is delegated to the global head of tax (who is based in the US) and UK based finance director. The day to day management of Virtusa UK tax affairs is provided by the finance team based out of UK, and consultation with external consultants as necessary. The global head of tax and UK finance director proactively manage tax issues and risk. They maintain a close relationship with the group's business to be involved in new initiatives and changes from planning to implementation to ensure that potential tax risks are identified in advance, and appropriate tax treatment is applied. Tax guidance provided is followed and clear timely guidance is given to the group's business managers on any tax matter that may arise. Virtusa seeks to reduce the level of tax risk arising from its operations as far as practically reasonable by implementing various internal controls for the various business units to follow. The group, maintains and utilises tax frameworks and process documentation used as part of compliance with the Sarbanes Oxley regime, and support is sought from UK tax advisors to ensure there is appropriate coverage of UK tax matters.
The group has a low risk appetite with respect to tax and will always aim to be transparent and open with tax authorities. We will, where necessary, consult with reputable external advisors to assist us in navigating any areas of uncertainty in the law, to keep us updated for any changes in law, and to help us ensure we remain compliant with any new obligations.
We act as a responsible global corporate tax citizen in compliance with applicable tax law and regulations. We encourage ethical and transparent business practices and do not employ legal entities for purposes of tax avoidance. The group will not participate in any structures that are consider illegal or risk adverse. The group does not and will not put in place any arrangements that are contrived or artificial where the sole purpose of which is to reduce UK tax. The group will also not engage in tax planning if the underlying commercial objectives and rationale do not support the position, or if the arrangements impact upon the UK group's reputation, brand, corporate and social responsibilities, or future working relationships with HMRC.
Relationship with HMRC
The group seeks an open, honest, transparent and constructive relationship with HMRC. The group will respond to HMRC requests on a timely and full basis. To the extent any inadvertent errors are made in submissions made to HMRC, these will be fully disclosed as soon as reasonably possible to do so. We encourage an open and honest dialogue between tax policy makers and business.