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Lebara’s Group Tax Strategy


This Tax Strategy is published to meet with Lebara’s UK obligations under paragraph 19(2) Schedule 19 Finance Act 2016. However, it applies to all companies in the Lebara Group BV group of companies.


The Tax Strategy has three main pillars:
• To ensure that all reported tax numbers are accurate and any statutory tax obligations are met in a timely manner.
• To manage the tax cost to the Group of undertaking its commercial activities in compliance with all applicable laws.
• To manage tax risks and the Group’s reputation through appropriate policies including open communication with stakeholders.

Attitude to risk

The Group is broadly risk averse. It wishes to be, and to be seen as a good corporate citizen. It does not seek conflict with the tax authorities. Consequently, the group does not seek to take advantage of artificial tax arrangements, being arrangements with no underlying commercial purpose. The Group does not consider the reduction of tax costs as a commercial purpose per se. However, the Group does seek to implement commercial decisions in a tax efficient manner within the boundaries of applicable law. Where we disagree with a tax authority ruling or decision we will first seek to resolve any disputed matters through pro-active and transparent discussion and negotiation. Ultimately, if necessary the Group is prepared to defend its position through the courts.


The ultimate responsibility for tax strategy within the UK rests with the Board of Lebara Limited, however the responsibility for the governance framework and management of tax risk rests with the Chief Financial Officer (CFO). The Senior Tax Manager is responsible for the implementation of the strategy and in ensuring the tax strategy is complied with on a day-to-day basis.

In terms of its dealings with HM Revenue and Customs, the Board promotes an open and cooperative approach.

Management of tax risk

Tax compliance and reporting

It is the group’s aim to file all required returns on time and in accordance with local tax laws, to settle all taxes due within deadlines and to ensure proper disclosures in the annual Financial Statements for all entities.

In order to meet its compliance obligation the group employs an experienced tax specialist in its London office; being the Senior Tax Manager. Tax advice is taken on matters when we do not have relevant experience or when in-house resource is not sufficient. For overseas jurisdictions, where appropriate, the Tax Function outsources its compliance to trusted Third Party advisers.

The Board supports the use of technology to improve the compliance process through the introduction of automation wherever possible.

Tax planning

In the context of the group’s overall Aim, it is sometimes necessary to seek advice from third parties in relation to material transactions (for example; the launch of new products, entry into new markets or the acquisition or disposal of companies or business assets). Primarily, this is to reduce tax risk by ensuring the appropriate level of expertise is brought to the transaction, but the group will look to secure any tax incentives and reliefs, introduced by Governments, to stimulate investment either internally or externally.

Relationship with tax authorities

We maintain an open, transparent and cooperative relationship with local and national tax authorities in the jurisdictions in which we operate. In terms of the UK we regularly meet with HM Revenue and Customs to discuss the business developments and tax matters. We acknowledge the support we receive from our Customer Relationship Manager (CRM) and the CRM’s team throughout the year.

In the event of a disagreement with tax authorities, it is the Group’s policy to conclude matters without unnecessary delay, hence the approach taken is to work openly and constructively with the tax authority.

The group’s Tax Strategy has been approved and agreed by the Lebara Group Board prior to publication.

Published in accordance with paragraph 19(2) Schedule 19 Finance Act 2016.