Allen & Overy LLP - UK Tax Policy

Approach to taxation

This policy applies to Allen & Overy LLP and all affiliated UK undertakings within the Allen & Overy grouping and sets out our approach to managing our UK tax affairs. It is founded against the standards and expected behaviours set out in our Global Code of Conduct. This underpins our values and requires all of our people to comply with applicable laws and regulations within a culture of integrity and honesty.

Tax principles

We are committed to compliance with all statutory tax obligations and disclosure requirements. This means making the appropriate tax filings and payments accurately and on a timely basis. It involves transparent disclosure of all relevant facts to tax authorities. This includes taking steps to avoid double taxation of the same income in two jurisdictions, and claiming applicable allowances and reliefs. We also expect all of our partners personally to comply with UK and international tax laws and not to engage in aggressive or abusive tax planning.

Tax risk management & governance

Due to the scale and complexity of our global business, and volume of tax obligations, we are exposed to inherent tax risks. We seek to actively monitor and manage these risks. Where there is sufficient uncertainty regarding a tax risk we will, having due regard to the quantum, seek appropriate external professional advice. Where significant matters arise we ensure appropriate escalation.

Ultimate responsibility for tax matters rests with our Board who review and approve this policy. Day to day responsibility for the management of our UK tax affairs is delegated to our Partners’ Affairs and Tax Team, who report to the Global CFO and Operations Director, with oversight from our Audit Committee.

Managing our tax affairs

Any structuring undertaken will be consistent with our Global Code of Conduct, with due consideration given to our reputation and responsibilities as a business as well as all applicable tax laws. This means that we do not engage in tax arrangements which are artificial or without commercial substance.

Engaging with HMRC

We seek to have a constructive and open relationship with HMRC, meeting regularly to provide updates on our business and highlight relevant tax matters. If there are areas of uncertainty we aim to resolve these through proactive dialogue, wherever possible.

This policy is published in compliance with the requirements of Paragraph 16(2) and Paragraph 25 of Schedule 19 to the Finance Act 2016. It applies for the financial year ending 30 April 2024 and all subsequent years until superseded.

March 2024