Intel Corporation (UK) Limited – Tax Strategy

Intel Corporation (UK) Limited (“Intel”) is an indirectly owned 100% subsidiary of Intel Corporation a U.S. company headquartered in Santa Clara, CA. Intel Corporation is a U.S. based manufacturer of advanced integrated digital technology platforms.

Approach to risk management and governance arrangements in relation to UK taxation

Intel is committed to conducting business ethically, with integrity, and in compliance with legal obligations, including our approach to taxation. Intel’s tax principles work in tandem with our Code of Conduct to promote honest and ethical business practices, deter wrongdoing, and support compliance with applicable laws and regulations. This focus on ethical business practices is the foundation of our global tax strategy.

The Chief Tax Officer is based in Santa Clara and is ultimately responsible for the overall tax strategy and policies. Day-to-day UK tax matters as they relate to Intel are assigned to the Associate Tax Director, International Tax Team, based in the UK and a team of in-house tax and accounting professionals who hold a combination of accounting and tax qualifications. We comply with all tax laws, regulations, and filing requirements in every jurisdiction in which we conduct business. We regularly review and maintain a corporate governance model that includes a tax risk management framework and procedures to identify, implement, and report on the design and effectiveness of internal controls. To complement our internal expertise, Intel regularly seeks advice from external tax advisors to ensure compliance with applicable tax laws, rules and regulations.

Intel’s Board of Directors is kept appraised and understand material business decisions and their tax impact.

The below applies to all UK entities as follows:

• Intel Corporation UK Limited
• Intel Research & Development UK Limited
• Codeplay Software Limited
• Optoscribe Limited

Approach to Tax Planning (so far as affecting UK taxation)

Our Code of Conduct serves as our guiding principle in our approach. We respect the tax laws and pay all taxes due as required in all jurisdictions in which we conduct business.

Intel maintains a tax structure consistent with its business operations. We participate in government sponsored tax incentives where they are made broadly available and in accordance with the relevant statutory, regulatory or administrative framework, especially where we conduct significant manufacturing or R&D activities.

Intel does not look to enter into transactions that have a main purpose of gaining a tax advantage nor to make interpretations of tax law that are opposed to its original spirit. We strive to reduce uncertainty in our tax matters, which may include seeking guidance using tax forums or tax rulings, as well as advance pricing agreements and other appropriate legal measures.

Intel does not use artificial tax avoidance schemes or use tax havens to reduce its UK tax liability. We adhere to the “arm’s length” principles, which are internationally accepted transfer pricing standards outlined by the Organization for Economic Cooperation and Development (OECD) and the UK. These widely adopted tax principles focus on a company’s functions, assets, and risks.

As a responsible taxpayer, Intel does not engage in any aggressive tax restructuring, tax avoidance schemes or offshore tax structures to artificially reduce the amount of UK tax it pays.

Level of risk in relation to UK taxation that it is prepared to accept

In reviewing the risks of a tax action or decision the following are all considered:

• The legal and fiduciary duties of directors and employees;
• The maintenance of corporate reputation;
• The tax benefits and impact on the Group’s reported result comparative to the potential financial costs involved, including the risk of penalties and interest;
• The wider consequences of potential disagreement with tax authorities, and any possible impact on relationships with them.

Approach towards its dealings with HMRC.

We engage with governments and tax authorities in a collaborative, timely, and transparent manner. We work to foster trust and cooperation with all tax authorities and are committed to resolving disagreements through open discussions.

We proactively work with HMRC and other tax authorities to provide full, fair, accurate, timely and understandable disclosures.

We seek to resolve issues with HMRC in real time and before returns are filed if possible, and where disagreements arise, work with HMRC to resolve issues by agreement.

Our strategy is compliant with the requirements of para 16(2) and 25(1) of Schedule 19, Finance Act 2016.