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Sonatrach Petroleum Corporation (SPC BVI) – UK Tax Strategy

This tax strategy has been published in accordance with section 19 (2) of Schedule 19 of the United Kingdom’s Finance Act 2016 in respect of SPC which is a branch in the United Kingdom for the financial year ending 31 December 2020.

Our business

SONATRACH PETROLEUM CORPORATION BVI (“SPC BVI”) was incorporated in the British Virgin Islands on May 3, 1989 in accordance with the International Business Companies Ordinance of 1984. On January 1, 2008 the company was automatically re-registered under the BVI Business Companies Act 2004.

The company has two offices, one located in London (SPC) and another in Algeria. These offices respectively provide administrative services for the activities that occur in these countries.

The company’s principal activity is the trading of oil and gas products, and shipping.

SPC BVI recognises that its businesses have responsibilities within the communities in which they operate. We therefore take our corporate social responsibility (“CSR”) seriously and are committed to advancing our policies and systems across the business to ensure we address and monitor all aspects of CSR that are relevant to our business. These include good ethical behaviour, concern for employee health and safety, care for the environment and community involvement.

In line with our commitment to corporate social responsibility, we endeavour to ensure the integrity of our tax affairs and to ensure compliance with all our tax obligations in the United Kingdom.

SPC BVI is committed to conduct its tax affairs consistent with the following objectives:

  1. Comply with all relevant laws, rules, regulations and reporting and disclosure requirements.
  2. Apply professional diligence and care in the management of all risks associated with tax matters, and ensure governance and assurance procedures are appropriate.
  3. Foster constructive, professional and transparent relationships with tax authorities based on the concepts of integrity, collaboration and mutual trust.

Our approach to risk management and governance arrangements in relation to UK taxation

SPC BVI is fully committed to complying with the tax laws in all the countries in which it operates. In the United Kingdom, the Board of Directors is ultimately accountable for tax, and they delegate responsibility for the day to day management of tax matters to the United Kingdom based Finance & Administration General Manager.

We are risk adverse and have robust controls in place in order to mitigate tax risks. Any Tax issues are escalated to the Board of Directors on a regular basis, enabling the Board of Directors to have visibility and control over tax matters.  We will also seek professional tax advice when we consider any transaction to be either outside the normal course of our business or encounter a complex tax matter and any advice will be reported to the Board of Directors for them to consider and act upon.

The level of risk in relation to UK taxation that we are prepared to accept

We have a low tolerance for tax risk in the United Kingdom, as we do in all the jurisdictions in which we operate.  Our attitude towards tax risk is primarily governed by the Board’s objective to minimise any tax risk and we therefore ensure that the Board of Directors has an appropriate level of oversight on tax matters.  Where we encounter any uncertain tax matters, we seek advice from a professional third party adviser to minimise tax risk.

Our attitude towards tax planning

We aim to ensure that all transactions we enter into are consistent with our commercial rationale, and tax is just one of the commercial factors that we consider when entering into a transaction. We seek to comply with all applicable tax law and utilise available tax allowances in the spirit in which they were intended by the legislation. We use reliefs and elections that are available to us, using specialist third party input when needed.

Approach towards our dealings with HMRC

In the United Kingdom, we aim to have an open, honest and transparent relationship with HMRC across all taxes.  We seek to raise areas of uncertainty with HMRC as soon as they arise in order to minimise tax risk and regularly liaise with our Customer Relationship Manager to discuss business changes, significant tax developments and to reach an agreement on certain tax positions.