Parkson Mobile UK Limited (“the Company”) – UK Tax Strategy

Parkson Mobile UK Ltd is a UK subsidiary company set up in 2019 by its parent company Multi Accord Ltd, which is based in Hong Kong, to be the main importer and distributor of mobile phones and mobile phones accessories under the brand ‘vivo’. The company is located in London.

This statement outlines the UK tax strategy of the Company, including the approach to tax risk management and governance, the attitude towards tax planning, the level of tax risk accepted and a description of the Company’s relationship with HMRC. As a member of a multinational group, the Company’s tax strategy is guided by the principles and the code of conduct of Lucky City Ltd.

The publication of this statement is considered to fulfil the Company’s obligations under Paragraph 22(2) Schedule 19 Finance Act 2016 for the financial year ended 31 March 2021. This tax strategy is intended to provide a clear and accurate outline of the Company’s approach to all aspects of tax reporting and compliance.

This tax strategy is owned and approved by the Board of Directors of Parkson Mobile UK Limited.

Approach to tax risk management and governance

The Company is a trading company, with its principal activity being the wholesale of electronic and telecommunications equipment and parts and is therefore subject to a range of UK taxes on its activities. The Board of Directors of the Company are committed to fulfilling their UK tax obligations through compliance with all UK tax law, regulations, and disclosure requirements. This commitment includes:

   · paying the right amount of tax at the right time;

   · filing complete and accurate returns on a timely basis;

   · seeking to utilise available tax reliefs and incentives where available in a manner which is in line with government policy; and

   · working with professional advisers in the UK to ensure compliance with UK tax law and practice.

The overall responsibility for the tax strategy of the Company rests with the Board of Directors. The day to day management of the Company’s tax affairs is undertaken by the Company’s finance team, who collaborate with the group finance team where necessary. The Company is supported by its professional advisers where appropriate.

The Company adopts a responsible approach to managing its tax affairs and seeks to comply with all statutory obligations. Third party advice is sought where it is considered appropriate; typically, where there is a material level of uncertainty or complexity.

The Company’s approach to tax risks follows the same principles that apply to other business risks and includes consideration of reputational and other non-financial risks. The Company aims to minimise tax risk by being tax compliant.

Level of tax risk accepted

The Company will only accept a low level of risk. The scale and complexity of the Company’s business and the volume of our tax obligations means that inevitably risks will arise. We ensure that where risks do arise, they are identified, evaluated and managed proactively in an open and ethical way. For certain transactions where there is a material level of uncertainty or complexity, we will seek external advice to help reduce risk.

Attitude towards tax planning

When structuring commercial activities and arranging transactions, the Company always considers the tax laws of the countries that they operate in. The Company does not participate in artificial tax avoidance schemes to reduce its UK tax liabilities. The Company only partakes in transactions that relate to genuine commercial activity with economic substance.

The Company does not seek to structure transactions in ways that produce tax results inconsistent with its underlying economic consequences. Any tax planning undertaken will have commercial and economic substance and will have regard to the potential impact on our reputation and broader goals.

The Company does not take an unreasonable stance on interpretation of tax legislation and strive to work within both the letter and spirit of local laws.

Relationship with HMRC

The Company does not have a Customer Compliance Manager or other dedicated contact with HMRC but acts collaboratively in an open and transparent manner in all dealings with HMRC.

The Company complies with all applicable tax laws and regulations, maintaining an open and honest dialogue in all dealings with HMRC. In the event of a disagreement with HMRC, the Company aims to resolve disputes in a timely manner through the provision of full and accurate answers to queries, open and honest dialogue and the willingness wherever possible to reach an agreement without recourse to litigation.

If faced with any uncertainty as to the application of certain tax laws, a proactive approach of engaging with HMRC in advance of undertaking any transactions may be adopted to confirm the correct application of tax law.

This strategy is owned and approved by the Board of Directors of Parkson Mobile UK Limited.

31 March 2021