ResMed ́s 2018 Tax Strategy

Introduction

ResMed changes lives with every breath.

ResMed (NYSE: RMD, ASX: RMD), a world-leading connected health company with more than 5 million cloud-connected devices for daily remote patient monitoring, changes lives with every breath. Our award-winning devices and software solutions help treat and manage sleep apnea, chronic obstructive pulmonary disease and other respiratory conditions. Its 6,000-member team strives to improve patients’ quality of life, reduce the impact of chronic disease and save healthcare costs in more than 120 countries.

General

This UK Tax Strategy defines the approach of the ResMed Group (the “Group”) to risk management and governance arrangements in relation to UK taxation. It applies to all UK entities in the ResMed Group (the “UK Subgroup”) and covers the UK Subgroup's attitude towards tax compliance, tax governance, tax planning and tax risk management as well as our approach to dealings with the UK tax authorities (HMRC).

Strategy and Mission 2020

The UK Tax Strategy has been derived from and is consistent with the Group's 2020 strategy. Our mission is to change 20 million lives by 2020. We're proud to make equipment and connected health solutions that give those with sleep apnea, COPD and other respiratory diseases the “gift of breath.”

Code of business conduct and ethics

Our code of business conduct and ethics summarizes the most basic rules reflecting how the UK Subgroup does business and is a commitment to responsible, ethically irreproachable and legally compliant behavior to the Group as a whole as well as to everyone at ResMed. The objectives and rules that govern this commitment are summarised in the Group's code of business conduct and ethics. The UK Tax Strategy is based on this code and leans on it, in order to ensure full compliance with all statutory obligations.

UK Tax Strategy

The UK Subgroup is committed to an open and transparent approach to its tax affairs. The UK Subgroup commits itself to:

  • Meet all applicable legal requirements;
  • Prepare and submit all appropriate tax returns on time;
  • Pay the appropriate amount of tax at the right time;
  • Seek to utilize available tax relief, credits, and incentives where available in a manner which is consistent with the government’s policy objectives;
  • Consider the tax impact of major or complex business decisions;
  • Operate in an environment where we consider tax in the context of our reputation and brand; and
  • Comply with appropriate tax risk processes, and ensure there is local General Management oversight into this compliance.

To achieve this, the European and Global Tax teams consist of tax professionals whose responsibilities include ensuring compliance with all relevant laws and regulations. The European and Global Tax teams manage tax risks with professional diligence and integrity and aspire to an open, honest, efficient, and constructive relationship with HMRC, other UK authorities, and other jurisdiction’s tax authorities.

Approach to risk management and governance arrangements

The Group Head of Tax owns and implements our approach to tax and is responsible for ensuring that policies, guidelines, and procedures that support this approach are implemented, maintained and used consistently. ResMed is committed to be compliant with tax laws in the jurisdictions where we conduct business. To be compliant while managing complex tax legislation and business operations, ResMed ́s global tax team as well as the European tax team is set-up and structured to ensure:

  • The UK Board of Management understands the importance of tax compliance and how it is achieved;
  • The UK Finance team, who drives the UK Finance processes, understands the importance of tax compliance, how it is achieved, and maintains open, honest and regular contact with the European tax team;
  • The European tax team is in regular contact with members of the Global tax team
  • That ResMed’s Global Tax Team communicates the fact that it adheres to an honest and fair approach to tax compliance when communicating to ResMed’s employees, business partners, and UK authorities.

ResMed fulfils its worldwide tax obligations by:

  • Monitoring and tracking tax relevant due dates worldwide;
  • Investing in software such as declaration and research tools;
  • Seeking external tax advice when necessary;
  • Developing an extensive preparation and review process for all global tax filings; and;
  • Investing in internal and external training for tax team members

Approach to tax planning and tax risk

The UK Subgroup takes a conservative approach to tax planning, consistent with the approach adopted throughout the Group. The UK Subgroup uses incentives to minimize the tax costs of business activities, but we do not enter into artificial arrangements designed to evade tax or defeat the intended purpose of tax legislation. Our tax planning is tied to and follows from the Group’s commercial objectives.

 

The European and Global tax teams consist of qualified, experienced, and dedicated tax professionals, including professionals who are responsible for strategic tax planning. They are generally able to manage the UK Subgroup's tax risks internally, but do seek external tax advice as needed. All of our tax planning ideas, whether implemented or not, undergo a risk assessment.

 

Tax risks arise from uncertainty regarding the interpretation of tax law. The European Tax team manages its tax affairs with professional diligence and integrity, which applies to all relevant transactions reported in our tax returns. Where errors or mistakes are discovered, we promptly disclose them.The European tax team has a responsibility to minimize tax risk and to maintain ResMed’s reputation as a responsible taxpayer and good corporate citizen.

 

Approach to dealings and relationship with HMRC

As our tax affairs are complex, they reflect a combination of the range of taxes that apply to our business and the cross-border dimensions that come from being an international group. We aspire to an open, honest, efficient and constructive relationship with HMRC, other UK authorities, and other jurisdiction’s tax authorities. However, the complexity of tax laws, guidelines, court decisions, and other regulations that relate to our business means that from time to time we may disagree with tax authorities on the technical interpretation of a particular area of tax law. We generally aim to resolve these disagreements through appropriate dialogue and discussion. Liaising with HMRC is performed by the European tax team, as well as by external tax advisers acting as our agents. We believe this builds a collaborative and constructive relationship with HMRC.

 

The publication of this UK Tax Strategy complies with the requirements of Finance Act 2016 Schedule 19 paragraph 16(2) for the financial year ending 30 June 2018 and remains in force until superseded.