MOODY’S CORPORATION
UK Tax Strategy for the Accounting Period ended 31st December 2023
Moody’s Corporation (“Moody’s”) is publishing this strategy statement on behalf of its UK subsidiaries and branches in relation to its approach to conducting its tax affairs and managing tax risks in the UK. This statement is made pursuant to the requirements outlined in Para 16(2), Schedule 19 of the Finance Act 2016.
Moody’s tax strategy is aligned with our overall approach to corporate governance and risk management, including our Code of Business Conduct. As with our broader business activities, integrity, honesty and ethical behavior guide our approach.
Moody’s Group UK organizational structure
This tax strategy statement applies to all Moody’s group companies and branches that are incorporated within the UK and/ or tax resident in the UK (collectively “Moody’s UK”).
Governance and Risk Management
Moody’s Chief Tax Officer has full ownership of our UK Tax Strategy and responsibility for its implementation. Day-to-day responsibility, including monitoring and controlling Moody’s UK tax affairs, is delegated to the Head of EMEA Tax who reports to the Chief Tax Officer. The Chief Tax Officer reports to the Chief Accounting Officer who in turn reports to the Chief Financial Officer who is ultimately accountable to the Audit Committee of Moody’s Board of Directors. The Audit Committee meets periodically with the Chief Tax Officer to review our tax strategy and policies.
Moody’s is committed to complying with all tax laws in the jurisdictions where it operates, including the UK. We maintain robust internal procedures and processes to support our global tax control framework and employ appropriately qualified and experienced personnel to properly identify, evaluate and manage tax risk. Professional care and judgment are employed to assess tax risks and to arrive at well-reasoned conclusions on how the risks should be managed.
Our tax function maintains close working relationships with our businesses in the UK and provides them with the appropriate guidance to ensure compliance with the UK tax laws. Engagement with stakeholders ensures that tax risks are identified in a timely manner and any appropriate mitigating action is undertaken. This results in open and transparent environment within which tax risk can be managed.
Moody’s recognizes that external tax advisors can add value, particularly when providing advice regarding new legislation and case law or in complex areas where further analysis is beneficial. All external advice is reviewed by the in-house tax team to ensure any outcome is consistent with our overall tax strategy and approach to managing risk.
Approach to tax planning
Moody’s complies with all tax rules and regulations on a worldwide basis and engages in tax planning that is aligned with our business operations. Moody’s recognizes that it has a responsibility to pay an appropriate amount of tax in each of the jurisdictions in which it operates and aims to balance this with its responsibility to its shareholders to structure its operations in an efficient manner. Any tax planning undertaken by us will have commercial and economic substance as well as regard for the potential impact on our reputation and broader business goals.
Transactions between Moody’s group companies, including its UK companies, are conducted on an arm’s length basis.
Level of tax risk
As a large, multinational organization, Moody’s and its UK subsidiary companies and branches can be exposed to tax risk. Where such risks arise, they are identified, evaluated and managed in a proactive manner. We monitor operations, tax structures and arrangements so that they comply with changing tax laws and regulations. We consult with external advisors when there is uncertainty as to the proper interpretation or application of tax laws or regulations related to a material transaction.
We fully support and comply with initiatives to improve international transparency on taxation matters, including OECD measures on country-by-country reporting and automatic exchange of information.
Open and transparent relationship with HM Revenue & Customs (HMRC)
Moody’s UK is committed to cooperate with HMRC in a professional and collaborative manner. We are committed to being transparent about decision-making, governance and tax planning. In the event of a disagreement with HMRC, we aim to resolve disputes in a timely and professional manner through full cooperation and with open and honest dialogue. Our objective is to reach agreement on such matters within a reasonable timeframe to remove uncertainty and mitigate tax risk.
Republished February 2024