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Tax Policy

Tax Policy

Introduction

Ülker Bisküvi Sanayi Anonim Şirketi (“Ulker” or “the Company”) Founded in a small workshop in 1944, Ülker Bisküvi is now one of the leaders of the biscuit industry in the world. One of Turkey’s leading food companies, we produce hundreds of different types of products in chocolate and cake categories in several locations. We manufacture our products in 10 factories, six of them are in Turkey (three - Silivri, Hadımköy, and Topkapı - in Istanbul, and one each in Karaman, Kocaeli, and Ankara) and four overseas (one in Egypt, two in Saudi Arabia, and one in Kazakhstan). We supply our products to consumers worldwide, including the Middle East, the Central Asia, Europe, Africa, Americas, and Russia, besides Turkey.

About Tax

Ülker is a compliant taxpayer in each country where it operates in. We have been creating value add for the economies operates in through the tax payments eg; salary tax, corporate tax, value added tax, sales tax and etc. made by the Group in different jurisdictions. The value added created by the Group via tax payment should be also considered as a critical element of our commitment to grow in a sustainable, responsible and socially inclusive way.

General Principles

As being a Global Group operating in XX of different jurisdictions, we have been monitoring tax legislation and regulations on timely manner with the support of local tax advisors and local accounting teams who have also good quality of tax knowledge and compliance awareness.

The Group is committed to complete accurate tax filings on a timely manner in accordance with the legal requirements in the jurisdictions that it operates.

All entities operating within the Group, as responsible taxpayers, pay taxes locally where its actual economic and business activities take place and in accordance with the way we operate business.

Tax organizations with adequate human resources, trainings and available systems have been developed and improved by the Group constantly.

The Group’s Tax Principles

Tax Compliance

The group acts in accordance with all applicable tax laws. The group acknowledges that tax evasion and criminal facilitation of tax evasion is illegal.

The Group minimizes its exposure to tax risk by being compliant with all tax rules and regulations globally. Where risks are identified, the Group consults to external tax advisors related to the interpretation of tax laws, rules or regulations. Specific to Turkey; our companies have been taking tax aduit service from Sworn Fiscal Advisors who controls our Turkish subsidiaries’ tax declarations and calculations on regular basis.

Transfer Pricing

The group aims to pay the appropriate amount of tax according to where value is created within the normal course of commercial activity and business. Transfer pricing is always calculated in accordance with the “arm’s-length” principle.

The Group aims to pay an appropriate tax based on economic and value contribution, according to where value is created based functions, assets and risks are taken. In intercompany transactions, the prices properly reflect where value is created.

Group’s transfer pricing policy conforms with international practices which is in accordance with the arm’s-length principle and is supported by economic analysis and documentation according to the nature of the transactions

Structure

The Group does not use any abnormal tax structures that are intended for tax avoidance, which have no commercial substance and do not meet the spirit of tax laws and principles. The Group does not engage in any operations or implement structures with the intent to inappropriately reduce taxes, such as contrived or abnormal tax structures.

Tax Heavens

The group does not use tax heavens for tax avoidance. The Group does not have operations in low-tax rate jurisdictions, “tax heavens” will not be used for tax reduction purposes.

Uncertainty and Tax Rulings

The Group seeks to avoid uncertainty and unexpected results in its tax position. If there is uncertainty in tax rules and practices at any country where the Group has operations, the Group actively engages with government authorities to clarify the applicable tax treatment and requests a regulatory guidance. The group applies for tax rulings from tax authorities to confirm the applicable treatment, based on full disclosure of the relevant facts.

Relationship with Tax Authorities

The group always keeps developing strong, mutually respectful relationships with tax authorities, based on transparency and trust.

The Group aims;

  • Developing good working relationships with tax authorities, government bodies and other related third parties, based upon mutual trust and respect that will ensure constructive dialogue
  • Playing an active role in discussing future tax legislation to better understand and minimize any negative impacts of such legislation on the Group
  • Proactively managing interactions with tax authorities to minimize the risk of challenges, disputes, or damages
  • Responding within designated timeframe to all requests received from tax authorities and communicating with related parties for any uncertainty arising from the interpretation of tax legislation.

Tax Incentives

The Group aims to utilize available tax incentives and exemptions aligned with commercial and economic activities. The Group makes investments in assets or engages in transactions which could be subject to tax incentives, or other tax exemptions and deductions which are authorized by laws in various jurisdictions.

The Group proactively researches and monitors all tax incentives in the countries that it operates, and benefits them when it is eligible.