UK Tax Strategies

ELFC London Limited – Year ending 31 December 2021
UK Company – Tax Strategy

Introduction
This document, in accordance with Schedule 19 of the Finance Act 2016 [“the Schedule”], sets out the UK tax strategy of ELFC London Limited. Hereafter references to ‘company’ or ‘companies’ refers to ELFC London Limited. ELFC London Limited regards this document as complying with the duty under para 22 (2) Schedule 19, Finance Act 2016 for the year.

The company and its shareholders are committed to full compliance with all statutory obligations and full disclosure to tax authorities.

This tax strategy applies to all taxes as set out in section 15(1) of the Schedule – this includes, but is not limited to, Income Tax, Corporation Tax, National Insurance Contributions, Value Added Tax and Stamp Duty Land Tax.

The tax strategy is approved, owned and overseen by the Board of the company.

In accordance with the Schedule, this tax strategy is available on Engine Lease Finance Group’s publicly accessible website www.elfc.com. The company forms part of the Engine Lease Finance group, being a wholly owned subsidiary of Engine Lease Finance Corporation.

Tax policies of the company
The Board’s objectives are to support the implementation of the company tax strategy while ensuring compliance with relevant laws and filing obligations to achieve the following overall policies in relation to tax:

the company will, at all times, pay tax in accordance with all relevant laws of the jurisdictions in which it operates,
the company will endeavour to fulfil all necessary tax obligations, including both payment and reporting obligations, in a comprehensive and timely manner,
the company will co-operate fully and transparently when dealing with all relevant tax authorities,
the company will endeavour to ensure that all information supplied to tax authorities is complete and accurate,
where material errors or misstatements are discovered in past filings, the company will immediately seek to rectify such errors,
the company will ensure that external advisors deliver their services in accordance with the company’s policy,
all intra-group transactions should be conducted on an arm’s-length basis in accordance with appropriate transfer pricing rules and OECD principles. Where necessary, such transactions should be appropriately documented,
the company will not accept risk of material tax exposure in respect of any transaction in which it is involved,
Company transactions will be subject to review by the company’s tax specialist.

Should taxes for which the company are responsible arise on a transaction, the company will, if practicable, pay such tax in accordance with all relevant laws of that jurisdiction, and

the company will endeavour to ensure that transaction documentation reflects the commercial agreement regarding apportionment of tax risk.

Approach to risk management and governance in relation to UK tax
Tax compliance issues are monitored in line with related deadlines and trigger events and where the tax treatment of certain items is uncertain, external advisers are engaged to provide expert advice. This policy ensures compliance with all relevant laws, rules, regulations, reporting and disclosure requirements in a manner that achieves the tax policy of paying the appropriate amount of tax at the appropriate time while also recognising the Board’s obligation to create sustainable value to shareholders. The company seeks to fully comply with its regulatory and other obligations and act in a way that upholds its reputation as a responsible corporate citizen.

Effective risk management is paramount for the company and underpins its business strategy. The level of risk that the company accepts is consistent with its overall objective of achieving certainty in its tax affairs. The company’s on-going tax risk approach is based on the above tax policies.

Attitude of the company towards tax planning
The company does not support or engage in aggressive or artificial tax planning, the sole purpose of which is to avoid UK tax or which disregards relevant legislation. The company maintains a strict policy of compliance with all applicable tax laws and regulations of the jurisdictions in which the company operates.

The company’s processes, policies and governance operate to ensure compliance with tax laws and regulations in jurisdictions in which it operates, and are designed to identify and mitigate tax risks. Due to the complexity of tax law and regulations, the company routinely receive advice from external advisors to ensure that the company is in compliance with local tax laws and regulations.

Level of risk in relation to UK tax that the Company is prepared to accept
The company is not prescriptive in terms of levels of acceptable risk, however the company’s strategic objective is to comply with legal requirements in the taxing jurisdictions in which the company operates, in a manner that ensures the right amount of tax is paid while creating sustainable shareholder value, underpinned by a tax policy based on an open, co-operative and transparent relationship with the tax authorities. The company would therefore consider themselves to be low risk from a tax perspective.

Relationship with HM Revenue & Customs [“HMRC”]
The Company understands the importance of communication with HMRC and will seek to work in ‘partnership’ with HMRC in relation to its tax affairs. The company is committed to co-operate fully and transparently when dealing with HMRC, and in particular commits to:

make fair, accurate and timely disclosure in correspondence and returns, and respond to queries and information requests openly and honestly in a timely fashion,
seek to resolve issues with HMRC in a timely manner, and where disagreements arise work with HMRC to resolve issues by agreement where possible,
be open and transparent about decision-making, governance and tax planning,
interpret the relevant laws in a reasonable way, and ensure transactions are structured consistently,
ensure all interactions with HMRC are conducted in an open, collaborative and professional manner, and
fully disclose and correct any inadvertent errors in submissions to HMRC as soon as is reasonably practicable after they are identified and to implement controls to ensure future compliance.

MC Engine Leasing Limited – Year ending 31 December 2021

UK Company – Tax Strategy

Introduction
This document, in accordance with Schedule 19 of the Finance Act 2016 [“the Schedule”], sets out the UK tax strategy of MC Engine Leasing Limited. Hereafter references to ‘company’ or ‘companies’ refers to MC Engine Leasing Limited. MC Engine Leasing Limited regards this document as complying with the duty under para 22 (2) Schedule 19, Finance Act 2016 for the year.

The company and its shareholders are committed to full compliance with all statutory obligations and full disclosure to tax authorities.

The tax strategy is approved, owned and overseen by the Board of the company.

the company will, at all times, pay tax in accordance with all relevant laws of the jurisdictions in which it operates,
the company will endeavour to fulfil all necessary tax obligations, including both payment and reporting obligations, in a comprehensive and timely manner,
the company will co-operate fully and transparently when dealing with all relevant tax authorities,
the company will endeavour to ensure that all information supplied to tax authorities is complete and accurate,
where material errors or misstatements are discovered in past filings, the company will immediately seek to rectify such errors,
the company will ensure that external advisors deliver their services in accordance with the company’s policy,
all intra-group transactions should be conducted on an arm’s-length basis in accordance with appropriate transfer pricing rules and OECD principles. Where necessary, such transactions should be appropriately documented,
the company will not accept risk of material tax exposure in respect of any transaction in which it is involved,
Company transactions will be subject to review by the company’s tax specialist.

Should taxes for which the company are responsible arise on a transaction, the company will, if practicable, pay such tax in accordance with all relevant laws of that jurisdiction, and

the company will endeavour to ensure that transaction documentation reflects the commercial agreement regarding apportionment of tax risk.

Approach to risk management and governance in relation to UK tax

Tax compliance issues are monitored in line with related deadlines and trigger events and where the tax treatment of certain items is uncertain, external advisers are engaged to provide expert advice. This policy ensures compliance with all relevant laws, rules, regulations, reporting and disclosure requirements in a manner that achieves the tax policy of paying the appropriate amount of tax at the appropriate time while also recognising the Board’s obligation to create sustainable value to shareholders. The company seeks to fully comply with its regulatory and other obligations and act in a way that upholds its reputation as a responsible corporate citizen.

make fair, accurate and timely disclosure in correspondence and returns, and respond to queries and information requests openly and honestly in a timely fashion,
seek to resolve issues with HMRC in a timely manner, and where disagreements arise work with HMRC to resolve issues by agreement where possible,
be open and transparent about decision-making, governance and tax planning,
interpret the relevant laws in a reasonable way, and ensure transactions are structured consistently,
ensure all interactions with HMRC are conducted in an open, collaborative and professional manner, and
fully disclose and correct any inadvertent errors in submissions to HMRC as soon as is reasonably practicable after they are identified and to implement controls to ensure future compliance.