Camfil tax strategy

Approach and Commitment to Compliance

Camfil is committed to full compliance with all statutory obligations and full disclosure to relevant tax authorities. Camfil’s tax affairs are managed in a way which takes into account the group’s wider corporate reputation in line with Camfil’s overall high standards of governance. 

Camfil AB, located in Sweden, is the parent company of the Camfil Group (“Camfil” or “the Group”) and has subsidiaries throughout the world in more than 30 different jurisdictions. This includes subsidiaries in the UK, which are referred to collectively as “Camfil UK” in this document, and defined in the final section.

Attitude towards tax planning and level of risk

Camfil manages risks to ensure compliance with legal requirements in a manner which ensures payment of the right amount of tax.

When entering into commercial transactions, Camfil seeks to take advantage of available tax incentives, reliefs and exemptions in line with, and in the spirit of, tax legislation.  Camfil does not undertake in artificial tax planning unrelated to such commercial transactions.

Camfil seek to enable the business to achieve its commercial objectives and accept that, given the scale of the Group’s business, this may involve taking on a degree of tax risk. Tax risk may arise from unclear laws, guidelines or differing interpretations, and may particularly result where transactions fall into the jurisdictions of two or more tax authorities who may take different views of the same facts and circumstances. Camfil seek to identify, evaluate, manage and monitor these risks in line with the Board’s attitude to tax risk.

Where appropriate, for example where there is significant uncertainty or complexity, we will work with specialist tax advisors to obtain independent advice and we may liaise with tax authorities to obtain greater certainty where this is possible.

The level of risk which Camfil accepts in relation to UK taxation is consistent with its overall objective of achieving certainty in the group’s tax affairs. At all times Camfil seeks to comply fully with its regulatory and other obligations and to act in a way which upholds its reputation as a responsible corporate citizen.

In relation to any specific issue or transaction, the Board is ultimately responsible for identifying the risks, including tax risks, which need to be addressed and for determining what actions should be taken to manage those risks, having regard to the materiality of the amounts and obligations in question.

Governance in relation to UK taxation

• Ultimate responsibility for Camfil’s global tax strategy and compliance rests with the Board of Camfil AB, the parent company located in Sweden;
• The Audit Committee’s requirement to monitor the integrity of Camfil’s financial reporting system, internal controls and risk management framework, expressly includes those elements relating to taxation;
• The Chief Financial Officer (‘CFO’) of Camfil AB is the individual with executive responsibility for tax matters;
• Day-to-day management of Camfil’s tax affairs is delegated to the Senior Vice President of Group Finance (and the associated Tax Team) located in Camfil AB, who reports to the CFO. This day-to-day tax management primarily focuses on transfer pricing compliance, and other areas of taxation for which the same transaction impacts multiple jurisdictions;
• The day-to-day management of other UK Taxation for Camfil UK is delegated by the CFO to the relevant UK Finance Director;
• The UK Finance Director is responsible for compliance with all UK Taxation, and will engage with specialist UK tax professionals to mitigate any risk of non-compliance.

Relationship with HMRC

Camfil look to develop and maintain professional working relationships with all tax authorities, in a spirit of co-operative compliance. Where tax audits are opened, Camfil aim to engage with tax authorities in a proactive and prompt manner in order to fairly resolve the matters under review.

Where we disagree with a ruling or decision of a tax authority or court, we will first seek to resolve any disputed matters through proactive and transparent discussion and negotiation. 

Camfil UK seek to have a transparent and constructive relationship with HMRC. When submitting tax computations and returns to HMRC, Camfil UK disclose all relevant facts and identify any transactions or issues where it considers that there is potential for the tax treatment to be uncertain.

Any inadvertent errors in submissions made to HMRC are fully disclosed as soon as reasonably practicable after they are identified.

Scope

This strategy applies to Camfil UK, which include the following UK corporate entities:

• Camfil Limited
• Bushbury Holdings Limited
• M C Air Filtration Limited

Camfil UK regards this publication as complying with its duty under paragraph 16(2) Schedule 19 FA 2016 in its financial year ended 31 December 2023.

This strategy applies from the date of publication until it is superseded. References to “UK Taxation” are to the taxes and duties set out in paragraph 15(1) of the Schedule which include Income Tax, Corporation Tax, PAYE, NIC, VAT, Insurance Premium Tax, and Stamp Duty Land Tax. References to “tax”, “taxes” or “taxation” are to UK taxation and to all corresponding worldwide taxes and similar duties in respect of which the Group has legal responsibilities.