UK Tax Strategy
Scope of policy
Pursuant to Schedule 19 of the UK Finance Act 2016, this document sets out the UK tax strategy of the three UK affiliates (the “UK group”) of Box, Inc. (“Box”); Box International Holdings, Ltd., Box International Technology, Ltd., and Box.com (UK) Ltd. Box considers that the publication of this tax strategy complies with its obligations under paragraphs 19(2) and 22(2) of the Schedule 19 for the year ended 31 January 2023.
Governance
The Box Chief Accounting Officer is responsible for the UK tax strategy. The Box Board of Directors and Audit Committee are informed about the UK group’s tax position and any material changes that may impact the overall business. The day-to-day tax matters are managed by both the local EMEA team, as well as the global internal tax function, which is predominantly located in the United States. Additional assistance from professional advisors is sought when required. In this respect, the group has defined clear lines of responsibility, ensuring that tax- related decisions are taken at an appropriate level.
Risk management
Box continuously monitors changes to tax law and changes in interpretations of UK existing tax laws as these changes could materially affect the UK group’s financial position. Any tax risk is managed by the tax function and/or by seeking external advice when there is uncertainty on the application of specific tax legislation. The tax function additionally partners with the business to evaluate changes in operations to ensure any new tax requirements are adhered to and that intercompany related activities are transacted in accordance with Organisation for Economic Co-operation and Development (OECD) transfer pricing principles. Box maintains timely and appropriate tax internal control procedures as part of the overall Sarbanes-Oxley (SOX) framework.
Tax planning
Box is committed to compliance with all relevant laws and the timely fulfillment of tax obligations in all countries which it operates. Box aligns the tax model with the group’s commercial and business strategy. Where incentives and reliefs are available, our decision to opt for a more favourable tax outcome must align with the group’s commercial objectives, meet our legal obligations, and consider the potential impact to our reputation. In circumstances where there are complexities with the tax laws or interpretations that may result in differing tax outcomes, Box engages external professional advisors for guidance.
Our relationship with HMRC
Box is committed to maintaining a collaborative and professional relationship in our dealings with HMRC and seeks a fair and constructive exchange of information regarding our business and tax affairs. The UK group’s current communications with HMRC are focused on timely return compliance and responses to queries.