BOC Tax Strategy

Linde Tax Strategy for the financial year 31 December 2023

Linde is a leading gases and engineering company with around 65,000 employees working in more than 80 countries including the UK. The strategy of Linde is geared towards long-term, profitable growth and focuses on the expansion of its international business with forward-looking products and services.

Linde has adopted a code of business integrity (the “Code”). It provides guidance on how Linde employees should conduct themselves with each other and with customers, suppliers, governments other businesses and our environment. It states that its employees should be bound by all local laws governing its business operations wherever located. The employees of Linde’s UK companies adhere to these standards.

This tax strategy applies to all Linde UK tax resident companies. The tax strategy is set out with reference to the UK sub-group (“Linde”) headed by Linde UK Holdings Ltd. It also applies to Linde plc (the parent of Linde), the UK sub-groups headed by Linde Investments No.1 Ltd, Linde Gas Holdings Ltd, Linde UK Holdings No.2 Ltd and Lansing Group Ltd and the companies Hydrogen Supplies Ltd, Refrigeration No.1 Ltd, Electrochem Ltd, Praxair Services (UK) Ltd, Praxair Offshore Services Ltd, Praxair Surface Technologies Ltd, Linde North America Holdings Ltd, Spectra Gases Ltd, Medispeed Ltd, Linde Canada Holdings Ltd, Noxbox Ltd and Linde Finance UK Ltd (which are not members of any UK group or sub-group) all of which are members of Linde. References to Linde should be read as references to the relevant UK sub-group or company.

Linde is aligned with and follows the Code and the wider Linde guiding principles and tax policy.

This tax strategy is approved by the board of directors of Linde UK Holdings Ltd (the “Board”) and sets out Linde’s approach to risk management, the level of risk it is prepared to accept, its governance arrangements in relation to UK taxation, attitude to tax planning and cooperation with HM Revenue & Customs.

It is compliant with the requirements of Schedule 19 of Finance Act 2016.

Approach to risk management

Linde is committed to managing its tax affairs in a responsible and transparent manner and to complying with applicable tax legislation.

Satisfying Linde’s tax obligations is a complex process due to its wide-ranging business activities and the ever-changing tax landscape. Uncertainties arise in the application or interpretation of law, resulting in tax risks.

Linde maintains robust processes and controls which are designed to minimise the risk of errors which could impact the amount of tax that it pays.

These processes and controls are regularly monitored, reviewed and tested and underpin the preparation and submission of its tax returns.

Level of risk in relation to UK taxation that Linde is prepared to accept

The level of risk that Linde accepts in relation to taxation is consistent with its overall objective of achieving as much certainty as possible with respect to its tax affairs. At all times Linde seeks to comply fully with its regulatory and other obligations and to act in a manner consistent with Linde’s commitment to best practice in corporate governance and responsible corporate citizenship.

In relation to any specific issue or transaction, the Linde’s senior director finance & control RUK (the "Senior Director Finance & Control) with oversight from the Board is responsible for identifying 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. Linde does not operate pre-defined limits as to the amount for acceptable tax risk; it is judged on an issue-by-issue basis.

Governance arrangements in relation to UK taxation

The Board is responsible for tax governance. The Board has delegated this responsibility to the Senior Director Finance & Control who reports to the Board as required.

In turn, the Senior Director Finance & Control has delegated responsibility for particular UK taxes to the appropriate department heads within Linde. Linde’s key taxes are managed day to day as follows:

UK tax Responsible person
Amounts for which Linde is accountable under PAYE regulations Payroll Manager
Value added tax Director of Accounting RUK
Corporation tax Executive Director Germany & UK Reporting and Compliance

The Executive Director Germany & UK Reporting and Compliance holds relevant professional qualifications and is required to maintain his professional competence via the continuing professional development requirements of these professional bodies.

The Executive Director Germany & UK Reporting and Compliance reports to the Vice President Tax & Treasury.

The competence of the UK tax team (which includes the Executive Director Germany & UK Reporting and Compliance) is ensured via annual tax training in accordance with their roles.

The UK tax team tackles technical queries on all taxes raised by other departments managing Linde’s various tax obligations.

External advice may be sought in areas of complexity or uncertainty to support Linde in meeting its tax strategy.

Attitude of Linde towards tax planning

Linde has a responsibility to its shareholder to structure its affairs in an efficient manner. Any tax planning activities undertaken shall be compliant with tax laws and supported by solid business reasons to sustain a credible long-term reputation with its stakeholders and in particular with the tax authorities. Profits are taxed with regard to the value chain. Linde does not engage in artificial tax arrangements.

Accordingly, it utilises tax incentives or opportunities for obtaining tax efficiencies where these:

(a) are not considered to carry significant reputational risk or significant risk of damaging its relationship with HM Revenue & Customs,
(b) are aligned with the intended policy objectives of the UK government in introducing the incentives, and
(c) are aligned with its business objectives.

Approach of Linde towards its dealings with HM Revenue & Customs

Linde engages with tax authorities with honesty, integrity and fairness and aims to be transparent and cooperative in its dealings with them.

In case of a disagreement concerning a ruling, interpretation or decision of HM Revenue & Customs Linde will first seek to resolve any dispute through pro-active and transparent discussion and negotiation.