Virtusa UK tax strategy

This tax strategy is published in accordance with paragraph 19(2), Schedule 19 of Finance Act 2016 and applies in respect of the following group companies:

• Virtusa Consulting & Services Limited

This strategy document applies for the year ended 31 March 2024 and will be reviewed and updated annually.

As part of a multinational group, we are aligned with Virtusa's guiding principles, code of conduct and transparent 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This strategy applies from the date of publication until it is superseded.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:

• All corporate income taxes
• Indirect taxes (VAT, Stamp Duty Land Tax)
• Employment taxes (PAYE / National Insurance / Construction Industry Scheme)
• Other applicable tax matters

Tax Risk Management

Ultimately the board of directors of the group companies are responsible for the tax affairs of Virtusa Consulting & Services Limited. This responsibility is delegated to the Global Financial Controller and Head of Tax. The day-to-day management of Virtusa UK tax affairs is provided by the finance team based out of the UK with operation support from offshore support of group companies’ team members, and consultation with external consultants as necessary.

The Global Financial Controller and Head of Tax 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 business units to follow.

The group conducts its tax operation within the guided principles and appropriate internal control environment referred through Sarbanes Oxley framework.

The group has appointed the UK Finance Controller as the Senior Accounting Officer (SAO) in line with UK Legislative requirements. As part of the SAO regime, the group has Risk and Control Matrices (RACMs) which are detailed to ensure compliance with internal controls and risk management. The Group has engaged external tax advisors and worked collaboratively to produce and refine the tax RACMs.

The operation of tax risk registers allows the business to identify, assess and manage the risks that the group is exposed to. Tax controls are subjected to a regular testing and monitoring programme to ensure their continued operating effectiveness.

The group engages intensely with reputed external tax advisors of the UK to ensure compliance operation and tax positioning of the group are commensurate with HMRC's prescribed rules and regulations.

Risk Appetite

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 reputed external tax 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.

Tax Planning

We act as a responsible global corporate tax citizen in compliance with applicable tax law and regulations. In line with our Code of Business Conduct and Ethics, we are committed to conducting business ethically. We encourage transparent business practices and do not operate legal entities for purposes of tax avoidance. The group will not participate in any structures that are considered illegal or risk seeking.

The group does not and will not put in place any arrangements that are contrived or artificial where the sole purpose is tax avoidance. 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. The group follows the OECD’s arm’s length transfer pricing principles.

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, including working with HMRC to seek clarification over the interpretation of tax law as relevant.

Updated March 2024
Reviewed and approved by the Board of Directors