Nissan Trading Europe Limited UK Tax Strategy
In accordance with Schedule 19 of the Finance Act 2016, Nissan Trading Europe Limited sets out below its tax strategy for its UK company for the year ending 31 March 2025 and which will be reviewed annually.
The UK Tax Strategy sits within a global Nissan framework.
Background – UK Operations
- Nissan Trading Europe Limited (NTE) operates in the UK.
- The principal activity of NTE as a logistics company is the import and export of Automotive parts, Machinery and Materials, mainly for use by other Tier 1 suppliers to the manufacturing plant at Nissan Motor Manufacturing (UK) Limited.
- NTE employs 41 people in the UK. Of these 40 are based at Sunderland and 1 in Cranfield.
- NTE is ultimately owned by Nissan Motor Co. Ltd., a company incorporated in Japan and so UK Tax strategy is governed by the wider global approach to tax by the Nissan Group.
- NTE operations and business in Europe completed a restructuring to better meet the challenges facing the group and automotive businesses in general.
1. Approach to risk management and governance arrangements in relation to UK taxation
There are several levels of control to limit tax risk and provide governance:
- The Nissan Global Code of Conduct sets out the integrity expected from employees, and this is reinforced annually with online training.
- The Senior Accounting Officer (SAO) regime and structure applies to the UK company and controls are in place to ensure correct tax accounting.
- Structured Delegation of Authority controls mean decisions on tax agreements (together with decisions on many areas) are subject to review and authorisation by local / regional / global senior management depending on the underlying value of the decision. This ensures both local and regional oversight of decision making.
- The UK Board of Directors is briefed on material tax issues and support this tax strategy.
- Tax risk is also managed through a conservative attitude to tax planning and open communication with tax authorities.
The inherent risk due to size, complexity and change is mitigated by:
- Tax and Customs functions from the wider Nissan UK group provide support and NTE Finance & Accounting functions are involved in key business decisions and general business awareness through the structured debrief cascade within NTE. This is enhanced through local Finance Manager overview of the functions.
- Customs function from the wider Nissan UK group provide overview and support of risk areas such as origin, destination, valuation and classification and broker selection.
- Analytical review of tax returns by NMUK Tax Manager, who looks after all Nissan entities in the Tax consolidation group, prior to submission to ensure they are supported by movements in the underlying business data.
- Taking external advice in complex specialist areas.
- Engaging with professional trade bodies to identify future risks and changes.
- Engaging with external professional company to support Transfer Pricing policy updates and Tax queries as applicable.
2. Attitude towards tax planning
- NTE operates within the Nissan global framework that sets a transparent approach to tax planning strategy. There is an obligation to shareholders to optimise tax efficiencies but set within the overriding context of compliance and brand reputation. NTE therefore does not use contrived structures or enter into non-commercial arrangements to reduce tax.
3. Level of risk in relation to UK taxation acceptable to Nissan
Nissan’s global brand reputation and the continuing success of the manufacturing and distribution operations are of paramount importance. Consequently, only a low level of tax risk is considered acceptable as demonstrated by proactive discussions with Tax Authorities on pricing arrangements and maintenance of our status as an Authorised Economic Operator.
4 Approach towards dealings with HMRC
- The trusted working relationship with HMRC is important to NTE and the ongoing engagement with the HMRC Customer Compliance Manager is highly valued.
- Open and ongoing dialogue with HMRC ensures transparency and helps to prevent unexpected issues arising for both NTE and HMRC.
- Discussions on uncertain or complex tax positions are conducted in a professional manner.
31 March 2025