Tax Strategy

Introduction

Sunovion Pharmaceuticals Europe Ltd. is part of a global group headed by Sumitomo Dainippon Pharma Co., Ltd. of Japan. Sumitomo Chemical Company, Limited is the ultimate parent company of Sunovion Pharmaceuticals Europe Ltd.

Sunovion Pharmaceuticals Europe Ltd.’s principal business activity is the distribution and sale of branded pharmaceutical products, in the UK market, and several other EEA countries.

Our approach to risk management and governance arrangements in relation to UK taxation

The tax governance of our business is led by the Board of Directors, which delegate’s responsibility for day to day tax matters to the General Manager and Finance Director.

Tax risks are identified across the business by those individuals and escalated as necessary to the Board. We routinely consult with Tax Advisors to consider implications on tax of business changes and to understand the relevance of changes in tax law for us. To ensure that tax returns are appropriately reviewed, there is a separate preparer and reviewer of our tax returns. Further, tax payments must be authorised in line with our approval matrix.

The Board and other senior management discuss business changes, including any associated tax consequences.

Tax compliance is in scope of audit by Group’s Internal Audit Team, who periodically visit our offices in the UK to review and determine the appropriateness of the controls in place over any significant tax risks.

Where there is complexity or uncertainty about our tax affairs we will also seek external advice to help us to reduce the risk of any non-compliance.

Our attitude to tax planning

We seek to be efficient with our tax affairs, appreciating that we have an obligation to the shareholders of our Group. However, our primary objective is to be compliant with the tax legislation and we ensure that our tax arrangements are aligned with the commercial reality of our business. Tax is merely one of the factors that we consider, together with other financial and reputational factors, in order to comprehensively judge our business transactions.

The level of risk in relation to UK taxation that we are prepared to accept

We have a low tolerance to tax risk. To minimise tax risks, any potentially significant tax risks are identified, assessed and controlled by the General Manager and the Company Secretary.

Approach to dealings with HMRC

The Group doesn’t have a Customer Relationship Manager (CRM) allocated by HMRC. Because our tax affairs are relatively straightforward, there is rarely a need to communicate with HMRC outside of our normal compliance process. When we do correspond with HMRC, we are open and transparent in our communications and we will voluntarily disclose any issues which may arise as soon as is practicable.

This Tax Strategy applies to the year ending 31 March 2018 and has been prepared in accordance with the requirements of paragraph 22(2) of Schedule 19 of the Finance Act 2016.

March 2018