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Santen UK Limited – Tax Strategy


The 'Santen Group', headed by Santen Pharmaceutical Co., Ltd, is a Japanese based international group, operating in the sectors of research, development, manufacture, marketing and distribution of specialised pharmaceutical products in the ophthalmic field.


Santen SA ('Santen EMEA') is the European headquarters company and incorporates the European, Middle Eastern and African divisions of the wider Santen Group.  The UK operations, Santen UK Limited ("Santen UK"), are part of Santen EMEA's remit.


This strategy applies to Santen UK in accordance with paragraph 19 of Schedule 19 of the Finance Act 2016 ("the Schedule").


This strategy applied from the date of publication until it is superseded.  References to 'UK Taxation' are to the taxes and duties set out in paragraph 15(1) of the Schedule which include Income Tax, Corporation Tax, PAYE, NIC, VAT, IPT, Stamp Duty Taxes, and Customs & Excise Duties. 


Santen UK is committed to full compliance with all statutory obligations and full disclosure to relevant tax authorities. Santen UK's tax affairs are managed in a way that takes into account the Santen Group's values ('Tenki ni Sanyo Suru'), The Santen Code of Practice, and is in line with the Santen Group's overall high standards of ethics and integrity in its conduct.

Governance in relation to UK Taxation

  • Overall responsibility for the Santen UK tax strategy and compliance rests with the Board of Santen UK Limited in combination with the Boards of Santen Pharmaceutical Co., Ltd and Santen EMEA, (together "the Boards").
  • The Boards requirement to monitor the integrity of Santen UK's financial reporting systems, internal controls and risk management frameworks, expressly include those elements relating to UK Taxation.
  • Executive Financial Management of Santen UK is delegated by the Boards to Santen EMEA's Chief Financial Officer and Santen EMEA's Financial Controller.
  • Day-to-day management of Santen UK's tax affairs is delegated to the UK Finance Manager, who reports to the Santen EMEA Chief Financial Officer.
  • The UK Finance Manager receives support from the Santen EMEA Tax Team.
  • The individuals responsible for UK Taxation are, and will always be, appropriately qualified individuals.
  • Certain UK Taxation compliance obligations are also out-sourced to external advisers.

Management of risk

  • Santen UK operates a system of tax risk assessment and controls as a component of the overall internal control framework applicable to the group's financial reporting system.
  • Santen UK seeks to reduce the level of tax risk arising from its operations as far as is reasonably practicable by ensuring that reasonable care is applied in relation to all processes, which could materially affect its compliance with its tax obligations.
  • Processes relating to different taxes are allocated to appropriate process owners, who carry out a review of activities and processes to identify key risks and mitigating controls.  These key risks are monitored for business and legislative changes which may impact them and changes to processes or controls are made when required.
  • Appropriate training is carried out for staff outside the core team who manage or process matters which have tax.
  • Advice is sought from external advisers, where appropriate.

Attitude towards tax planning and level of risk

Santen UK manages risks to ensure compliance with legal requirements in a manner which ensures payment of the right amount of tax at the right time.  When entering into commercial transactions, Santen UK only seeks to utilise available tax incentives, reliefs and exemptions in line with, and in the spirit of, tax legislation. 


Santen UK uses the following parameters to determine whether tax risks presented by the adoption of any particular tax planning opportunity are acceptable or not:

  • Commercial purpose
  • Reputational impact
  • External professional advice

In relation to specific, significant transactions, the Santen EMEA Chief Financial Officer is ultimately responsible for identifying the risks, including tax risks, which need to be addressed and for determining what actions should be taken to manage those risks, having regard to the group's general approach to risk management.


The level of risk which Santen UK accepts in relation to UK Taxation is conservative and consistent with its overall objective of complying with local tax laws and to act in a way which upholds its values and reputation as a responsible corporate citizen.   

Relationship with HMRC

Santen UK seeks to have a transparent and constructive relationship with HMRC.


When submitting tax computations and returns to HMRC, Santen UK discloses all relevant facts and identifies any transactions or issues where it considers that there is potential for the tax treatment to be uncertain.


Any inadvertent errors in submissions made to HMRC are fully disclosed as soon as reasonably practicable after they are identified.