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External Tax Strategy and VIth INTERNATIONAL INDUSTRY CONFERENCE ON 20-21 SEPTEMBER, 2018 MINSK

BNK (UK) Limited (“BNK”) is a member of the BelOil Group. BNK’s principal activity is the wholesale trading of fuels and other oil products and, in addition, BNK provides intermediate services to oil sector companies in the Republic of Belarus through: negotiation of contracts for the supply of fuels and other oil products to national and international oil trading companies in North West Europe; negotiation of trade finance with banks and other financial institutions; and arranging contracts with shipping and oil terminal companies.

In its business activities BNK is guided by its commitment to social accountability. This refers both to the company’s cooperation with its business partners and its activities at internal and governmental levels. In its activities BNK focuses upon support of the socially important spheres of public life such as health care, sport and public welfare. BNK’s overall objective for tax is therefore to comply with all relevant compliance and reporting obligations in line with its commitment to social accountability. This objective also supports BNK in the achievement of its business objectives by providing certainty over its tax affairs.

Approach to tax risk management and governance: BNK and the BelOil Group are committed to operating an effective tax control framework to ensure that its tax filing and reporting obligations are identified and met, and tax risks are proactively mitigated to acceptable levels. Relevant BNK tax risks are reported into the overall Group framework as appropriate. The Board has ultimate oversight of, and accountability for, BNK’s tax affairs. The Board reviews and monitors the key tax risks facing the business, as well as the internal control procedures that have been implemented to manage these risks. The Director is ultimately responsible for the execution of our documented policies, and for assessing the adequacy and effectiveness of internal controls. Day to day responsibility for compliance with the UK Tax Strategy and monitoring of the tax control framework sits with Finance Manager who reports directly to the Director as necessary.

Attitude towards tax planning: BNK strives to pay the correct amount of tax in accordance with applicable legislation. There is an acknowledgement that tax is a cost to the business and, in order to achieve BNK’s business objectives whilst maintaining certainty over its tax affairs, consideration is given to the most tax efficient way to conduct commercially driven business transactions. No transaction is entered into with the primary purpose of achieving a tax advantage, and BNK does not undertake any aggressive tax planning using artificial tax structures without commercial substance. All intra-group transactions are executed at arm’s length in line with the OECD’s Transfer Pricing Guidelines and supported by Transfer Pricing documentation. Where tax legislation is unclear or subject to interpretation external tax advice is sought, as necessary, to provide certainty and ensure full compliance.

Level of risk in relation to taxation that we are prepared to accept: BNK’s risk appetite for tax is low. BNK will not engage in any activities that may harm the reputation of BNK or the wider BelOil Group in relation to its tax affairs. BNK, in consultation with external tax advisers, monitors its tax compliance and reporting obligations to ensure sufficient and appropriate oversight with the objective to minimise both the likelihood and impact of tax risks arising from its operations.

Approach towards dealings with HMRC: BNK seeks to be transparent and open in its relationship and dealings with HMRC through proactive engagement and full and timely disclosure of necessary information as required by law, including in relation to past, current and future tax risks. Efficient and early resolution of any HMRC enquiry is sought, and BNK will engage fully and openly with HMRC to facilitate this. In the event of uncertainty over tax laws reputable external tax advice is sought and, where necessary, HMRC may be consulted.


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