UK Tax Strategy

The strategy, as outlined above, is consistent with the rest of the Salesforce group and also with the Group's Code of Ethics. It is aligned with  Salesforce’s broader values,  the  most important of  which  is trust.  This document is owned  by the Board of Directors of salesforce UK Limited (“the Board”) on behalf of the UK Group. It will be reviewed annually, updated as appropriate and approved by the Board. The Board has delegated responsibility for the implementation of the tax strategy to the salesforce.com, inc. Group Tax and Controllership Teams (“SFDC Tax & Finance”).  SFDC Tax & Finance strive to build and maintain relationships across the business to promote and embed the need to  take tax compliant business decisions. The in-house group tax function also works to ensure that appropriate and ongoing monitoring of tax risks affecting the UK is performed and adequate mitigation is effected where needed.  SFDC Tax & Finance report back to the board on an ongoing  basis via  the Vice President of  EMEA Controllership  and  through quarterly tax updates.

The UK  Group  is committed  to  compliance with  UK  tax laws. Compliance, in  this instance, means adhering to  all relevant UK tax legislation. This legislation covers, inter alia, paying the correct amount of tax to the relevant authority at the appropriate time, disclosing relevant facts and circumstances to the tax authorities and legitimately claiming government reliefs and incentives where available.

Salesforce has a zero tolerance approach to tax evasion and the facilitation of tax evasion by its employees and associated third parties. Tax evasion is where there is a deliberate, illegal attempt not to pay the tax which is due.

In structuring its commercial activities the UK Group will consider, among other factors, local tax laws, with a view to maximising value on a sustainable basis for its partners and employees. Any structuring that is undertaken will give due regard to commercial and economic substance and to the potential impact on the UK  Group's reputation  and  broader goals.

SFDC Tax & Finance are staffed by qualified experienced professionals.  Due to  the increasing  complexity  of  tax laws and the  multi-jurisdictional  implications of  transactions and  business operations,  SFDC Tax & Finance  may  seek external advice in certain instances from professional service firms and / or subject matter experts.

Given the scale of business and volume of tax obligations, risks will inevitably arise from time to time in relation to the interpretation of tax laws and the nature of the UK Group's compliance arrangements.

The UK Group actively seeks to identify, evaluate, manage and monitor these risks to maintain compliance, minimise financial penalties and protect the business reputation of the UK Group. It seeks to reduce the level  of  tax risk arising from its operations, as far as is reasonably practicable, by ensuring that due care is taken in relation to processes that affect its compliance with tax obligations. Processes relating to different taxes are assigned to  appropriate  process owners in SFDC Tax & Finance functions and across the business who review activities and monitor appropriateness and performance of controls.

Where there is significant uncertainty or complexity in relation to a risk, external advice may be sought.

The UK Group  engages with  taxing  authorities, including  HMRC, with  honesty, integrity, respect and  fairness.  In  the event of any inadvertent errors in submissions made to HMRC or other tax authorities, or in interpretation of relevant legislation, appropriate disclosures will be made as soon as possible after they are identified. The UK Group will seek to resolve any disputed matters through pro-active and transparent discussion and negotiation.