UK Tax Strategy

What is the strategy?

1. Background and scope

This strategy applies to all taxes relevant to If P&C Insurance Ltd’s (publ) (If’s) business in the UK and takes effect from the date of publication until superseded or otherwise replaced. This strategy is published in accordance with paragraph 19(2) of Schedule 19 of the UK Finance Act 2016.

2. Aim

If is committed to ensuring full compliance with all statutory obligations and full disclosure to the relevant tax authorities. If views tax compliance as an important part of its corporate social responsibility both as an insurance company and as a member of a listed group of companies.

If’s governance model, the applicable mandatory requirements and the supervision carried out by the financial supervisory authorities, ensure that If maintains a high standard of governance and compliance.

3. Governance in relation to UK taxation

The Board of Directors of If has the responsibility for both the taxation requirements as well as the tax strategy of If’s UK Branch. The local branch manager has the first line responsibility for issues related to taxation in the UK.

4. Tax risk management

UK tax risks are managed as part of If’s global tax risk management.
If has a system of assessing its tax risks, which includes operational and compliance risks as well as legal development.

The system operates in accordance with the instructions and controls of the If governance
structure, and If’s Board of Directors evaluates the system’s compliance with the relevant
legislation and regulations. If has a Corporate Accounting and Tax department that has responsibility to manage tax risks and report them internally to the If Group’s Chief Financial Officer (“CFO”) and If’s Tax Committee.

The Tax committee is led by the CFO and gives its opinion on material tax strategy issues, including both direct and indirect taxation, to the CEOs of the respective If P&C companies. The TaxCommittee also provides advice on co-ordination and handling of significant group tax issues.

The CFO has the executive responsibility for tax matters and reports to the Board of Directors of the If P&C entities in question. The work of the Corporate Accounting and Tax department is supported by local experts in If’s main operating countries. Further assistance by local external advisers may be sought in order to reduce potential tax risks.

Key risks and mitigating activities are identified and reported by the applicable organizations and their personnel in the respective countries. Any changes or new requirements are implemented as part of this process.

If also has a system into which all employees can report any type of incidents, including tax events. Inadvertent errors in submitted tax returns will be fully disclosed as soon as reasonably practicable after their identification.

This process and the underlying risks are controlled in accordance with the governance model and they are reviewed by the auditors, internal auditing and internal control.

5. Tax planning and tax risks

If seeks to pay taxes in a consistent and coherent manner in all of the countries in which it is
If takes a conservative approach towards tax risk. If seeks to be efficient with its tax affairs and, in this context, will respond to tax exemptions and incentives only where they are compliant with laws and the intentions of legislators and support sound commercial business activity that is aligned to If’s business strategy. If seeks advice on relevant tax issues from both external advisors and from the relevant tax authorities in the form of meetings, advance rulings and tax opinions.

When providing significant transaction support or undertaking significant business decisions, If carries out its evaluations within key tax risk parameters and will only accept business models that pose a low tax risk. When deciding on what is acceptable, consideration is given to If’s reputation,
brand, corporate and social responsibilities. If seeks to manage tax in the responsible manner that is expected by its shareholders and customers.

All transactions must be driven by business needs or commercial rationale and no transaction can be artificial in nature aimed solely at seeking a tax advantage.

Relationship with HMRC

If is committed to maintaining an open and co-operative relationship with HMRC. If submits tax computations with all of the relevant facts and also highlights any and all reportable transactions.

Where necessary, If will use an external local tax advisor in assessing tax risks, tax events and local regulatory requirements in the UK and in its contacts with HMRC. As stated above,

If will participate in meetings with HMRC, obtain tax opinions and apply for advance rulings where necessary in order to secure If’s tax position.

Decided by:

CEO of If P&C Insurance Ltd (publ)

Valid from Jan 1st 2024

This document shall be reviewed and decided at least yearly.