This UK tax strategy applies to SB Energy Global Holdings Limited and SB Energy Global Holdings One Limited (“UK Entities”) for the years ending 31 March 2025 and 31 March 2026.
The SB Energy Tax Team (“SBE Tax”, “We”) manages tax matters for SB Energy Global Holdings Limited and SB Energy Global Holdings One Limited.
We publish this tax strategy in compliance with the UK Entities’ obligations under paragraph 19(2) and 22(2) of Schedule 19 of the Finance Act 2016. This policy was reviewed and approved by the Chief Compliance Officer, and the directors of SB Energy Global Holdings Limited and SB Energy Global Holdings One Limited in December 2025.
GOVERNANCE
Responsibility for UK tax governance, strategy and management ultimately sits with the respective UK
entities’ Board and Executive Management Team. Day-to-day responsibility for these areas has been delegated
to the SBE Tax Director.
How UK tax risks are managed
UK tax risks are managed by ensuring we leverage the right people, processes and technology, which are all
supported by a robust control framework.
People
An important component of our UK tax risk management is SBE Tax and Accounting working with reputable
professional firms to ensure that the UK Subsidiaries comply with their legal obligations in relation to tax
filings, reporting, and payments.
Processes and Technology
We ensure that we have appropriate processes and technology in place to help us manage tax risk:
- Use of financial management tools.
- A standardized review process for tax returns, payments of taxes and reported tax positions.
- Accounting, treasury, legal and accounts payable processes to support SBE Tax but that operate separate
approval processes and appropriate separation of duties. - Regular communication with external tax specialists when new tax compliance obligations are announced
and/or new processes are implemented.
Controls and Review
SBE Tax in conjunction with SBE Accounting owns, operates and monitors the effective operation of tax
controls. Any breaches are reported to the Chief Compliance Officer. Annually, tax risk owners and control
owners discuss and review and sign off on the effectiveness of the control framework. The SBE Tax Director
completes the process by reviewing the assessment from the risk and control owners to confirm that the tax
risk is within predetermined tolerable thresholds. The SBE Tax Director makes the final certification,
highlighting any issues to the Chief Compliance Officer and an action plan is agreed, if required.
Internal Audit provides an independent objective assurance service to the Board and senior management to
confirm the UK Subsidiaries’ risk management, governance and internal control over financial reporting
processes are operating effectively. Internal Audit performs annual control assurance test programs, and all
reported corrective actions are followed-up to completion.
Attitude to UK tax planning
We acknowledge our responsibility to pay an appropriate amount of UK tax in line with our business activities
in the UK. We also recognize that we have a fiduciary responsibility to our stakeholders to realize our
commercial objectives in a tax efficient way.
In line with the above statements we aim to ensure that the UK tax paid on our business activities is based
on a reasonable interpretation of the intention of the UK tax legislation and that our activities do not
result in unanticipated tax costs for our stakeholders.
We will not undertake any UK tax planning where there is no commercial motive for a transaction and the only
purpose is to create a tax benefit.
Level of acceptable risk for UK taxation
Our level of acceptable risk is consistent with the UK Entities overall objective of achieving certainty in
tax affairs. At all times, the UK Entities seek to comply fully with their regulatory and other obligations
and to act in a way which upholds their reputation as responsible corporate citizens. In relation to any
specific issue or transaction, ultimately, we seek to identify the risks, including tax risks, which need to
be addressed and consider what actions should be taken to manage those risks, with regard to the materiality
of the amounts and obligations in question.
Working with HMRC
Our aim is to work cooperatively with HMRC through an open and transparent relationship.