The UK Tax Strategy of the Emirates NBD Group

Emirates NBD, is a leading banking group in the Middle East, and was formed in October 2007 as a result of the merger of Emirates Bank International and the National Bank of Dubai.

Our UK presence originated in 1986 with the creation of our London Branch (“Emirates NBD UK”), which focuses on three main business lines: Private Banking, Wholesale Banking, and Treasury.

This document outlines the Group’s tax strategy in relation to the business activities of Emirates NBD in the UK, in accordance with the requirements of Paragraph 16(2) Schedule 19 Finance Act 2016 which applies from 1 January 2017.

Our UK tax affairs are conducted in accordance with the following principles:

• Complying with all applicable laws and regulations relating to its tax activities, including disclosure obligations;
• Meeting all legal requirements and compliance obligations, including filing all appropriate tax returns and making all applicable tax payments on a timely basis;
• Dealing with tax authorities in an open, honest and transparent manner;
• Undertaking a low appetite for tax risk where tax consequences arise only in the context of wider business activities having a commercial economic basis;
• Maintaining internal accounting systems and controls that are sufficiently robust to support our tax compliance obligations.

Approach to Risk Management and Governance

Emirates NBD London Branch is committed to promoting good corporate governance and considers it to be a critical part of our goal of creating long-term value for all stakeholders. Transparency and accountability are central to Emirates NBD London Branch's business.

As a regulated business, we are committed to operating in a prudent and responsible manner, with a strong control environment. We are regulated by the Prudential Regulation Authority (‘PRA’) and the Financial Conduct Authority (‘FCA’). As part of the Senior Managers and Certification Regime required by the PRA and FCA, we have a specific Finance Senior Manager who is responsible for oversight of the Finance activities.

We have internal tax risk management procedures and practices in place to ensure that we fulfil our tax obligations. Responsibility for managing the UK tax matters fall within the direct responsibility of the UK Finance Team and the UK Senior Finance Manager, who ultimately report to the General Manager in the UK and ultimately to the Board via control and support functions located at our Head Office in Dubai.

Emirates NBD London Branch engages external tax professionals to assist with its ongoing UK compliance requirements, including corporation tax, VAT and employment taxes. External professional advice is also sought when considering the impact of new tax legislative developments.

More details on Emirates NBD’s corporate governance can be found on our website.

Attitude to Tax Planning

All of Emirates NBD London Branch’s activities are commercially and business driven and targeted tax planning is not a consideration of our overall business planning. The key components of our attitude to tax planning are:

• We are committed to paying the correct amount of tax in relation to all of our business activities;
• We do not structure our transactions, or those of our clients, where the main purpose is to gain a tax advantage or to divert profits from higher tax rate jurisdictions;
• All related party transactions are undertaken in accordance with OECD principles and UK tax legislation;
• Our prime performance indicators for income generating employees are assessed on the operating profit or pre-tax positions only;
• Where any complex or unclear tax positions arise, we seek the advice of external tax specialists to support our decision making.

Overall, Emirates NBD London Branch’s approach to tax on our business activities is to ensure that we comply with both the letter and spirit of the legislation.

Risk Appetite

Emirates NBD London Branch’s approach to risk across the wider business is reflected in our low tax risk appetite and is fully supported by our internal governance structure:

• We are committed to complying fully with the spirit and letter of all relevant laws and disclosure obligations in the UK;
• We operate in accordance with the UK Code of Practice on Taxation for Banks (‘Banking Code’);
• We pay all taxes due and do not enter into non-commercial transactions which give an artificial tax result.

Approach to Dealing with HMRC

In line with the requirements of the Banking Code, Emirates NBD London Branch maintains an open and transparent relationship with HMRC on UK tax matters:

• We engage proactively and co-operatively with HMRC to discuss our tax matters;
• For tax items that are sufficiently material and where we view as having more than one interpretation, we look to enter into dialogue with HMRC at the earliest opportunity;
• We raise concerns with HMRC and / or obtain pre-authorisations with the ultimate goal being to resolve any disputes in a professional manner before our tax returns are filed.