Tax Strategy

Sonatrach Gas Marketing UK Limited (“SGM UK”) – UK Tax Strategy

Under the tax provisions of the United Kingdom, there is a legal requirement for a qualifying corporate business organisation to publish its Tax Strategy, as it relates to UK taxation.

Accordingly, this Tax Strategy has been prepared and published in accordance with Paragraph 22(2) Schedule 19 Finance Act 2016 by SGM UK, a company formed and registered pursuant to the UK’s corporate codes.

This Tax Strategy relates to the financial year end 31 December 2024 and shall be effective from its publication until superseded or otherwise replaced and shall apply to UK taxation as prescribed by Paragraph 15 Schedule 19 Finance Act 2016.

SGM UK’s commercial activities

SGM UK was incorporated in the United Kingdom on 7 December 2005, in accordance with the Companies Act 1985. SGM UK has one office, located in London, UK, and the company’s principal activity is the trading and supply of liquefied natural gas (“LNG”).

Compliance with UK tax law, regulations and practice

SGM UK adopts a conservative approach to tax risk and ensures accurate and timely filing of returns and payments of tax. SGM UK conducts its tax affairs with integrity.

The management of SGM UK’s tax affairs are undertaken so as to identify, manage and minimise to the greatest extent possible UK taxation risks to the company. This ensures that UK taxation compliance obligations are met.

In line with SGM UK’s UK taxation objectives, the company conducts its tax affairs in a manner consistent with the following principles:

  1. Maintains strong UK tax compliance systems and practices, which includes the accurate and timely preparation and filing of UK tax returns and the payment of UK tax.
  2. Complies with all relevant laws, regulations and practices and satisfies reporting and disclosure requirements.
  3. Applies professional diligence and care in the management of UK taxation risks and ensures governance procedures and frameworks are appropriate to the risk being managed.
  4. Identifies, evaluates, monitors and manages tax risks, and tax-related regulatory risks.
  5. Fosters constructive, professional and transparent relationships with key stakeholders including, but not limited to, HM Revenue & Customs (HMRC), based on the principles of integrity, collaboration and mutual trust.

SGM UK’s approach to risk management and governance arrangements in relation to UK taxation

Responsibility for UK taxation oversight governance and the implementation and adherence of the Tax Strategy rests with SGM UK’s Board of Directors.

The Head of Finance & Administration is responsible for the day to day management of UK taxation matters. The Head of Finance & Administration reports directly to SGM UK’s Board of Directors.

SGM UK is risk averse and the company has embedded within its finance systems robust controls to mitigate UK taxation risks. These controls are reviewed on a regular basis to ensure they remain effective and appropriate in managing SGM UK’s taxation risks. For example, the SGM UK ensures that appropriate tax risks and tax accounting arrangements are maintained in line with the Senior Accounting Officer regime.

Tax matters are communicated to the Board of Directors on a regular basis, providing visibility and control over the management of UK taxation matters.

As a matter of practice, SGM UK is also supported by professional advisors and obtains professional tax advice including on matters and transactions that are outside the normal course of business or complex in nature. Any such advice is appropriately reported to the Board of Directors for its consideration and approval.

SGM UK manages its UK taxation affairs to ensure that it pays the right amount of tax, consistent with UK tax law and prevailing practice. This involves disclosing all relevant facts and circumstances to HMRC and claiming UK tax reliefs and incentives, where available. SGM UK does not enter into artificial arrangements.

SGM UK’s attitude towards tax planning

Tax risk is one of a number of commercial risks that SGM UK is exposed to given the nature of its operations.

SGM UK aims to ensure that all transactions entered into are consistent with its commercial rationale.

SGM UK adopts a low-risk approach to tax planning. This approach to tax is reflected in the low risk relationship with HMRC.

SGM UK complies with all applicable UK taxation laws and utilises available tax allowances, reliefs and elections that are available to the company, using specialist third party professional advisor advice, when needed. SGM UK does not enter into artificial arrangements so as to avoid UK taxation.

The level of risk in relation to UK taxation that SGM UK is prepared to accept

In line with SGM UK’s low risk approach to tax, it has a low tolerance for tax risk.

SGM UK’s attitude towards tax risk is primarily governed by the Board of Directors’ objective to minimise any tax risk and the company therefore ensures that the Board of Directors has an appropriate level of oversight of tax matters.

The level of risk which SGM UK accepts in relation to UK taxation is consistent with the company’s overall objective of achieving certainty in its tax affairs. At all times, SGM UK seeks to comply fully with its UK taxation obligations and to act in a way which upholds the company’s reputation as a responsible corporate citizen.

SGM UK’s approach towards its dealings with HMRC

SGM UK has an open, honest and transparent relationship with HMRC across UK taxation. In this respect:

  • SGM UK seeks to raise areas of uncertainty (if any) with HMRC as soon as they arise;
  • SGM UK always responds promptly and fully to any requests from HMRC; and
  • As a large UK business, SGM UK is proactive in ensuring that there is an open and collaborative relationship with the company’s HMRC Customer Compliance Manager.

In line with approach to UK taxation, SGM UK maintains a low risk relationship with HMRC, which includes periodic meetings with its HMRC Customer Compliance Manager.