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1. Introduction

1.1 Background

The Barry-Wehmiller Group is a privately owned multi-national enterprise. The ultimate parent company is Barry-Wehmiller Group Inc which is incorporated in the United States of America.

The UK sub-group is comprised of the following companies:

Active Companies:

• Accraply Europe Limited
• Apollo Sheeters Limited
• Baldwin Technology Limited
• BW Flexible Systems UK Limited
• BW Integrated Systems UK Limited
• Paper Converting Machine Company Limited
• PneumaticScaleAngelus of the UK Limited
• Quadtech UK Limited

Inactive Companies:

• Acrotec UK Limited (in Liquidation)
• Baldwin UK Holding Limited (in Liquidation)
• Baldwin (UK) Limited (in Liquidation)
• Primarc Limited

This document sets out the strategic tax objectives of the UK sub-group.

1.2 Approval

The Group鈥檚 Finance Director is responsible for leading the Tax Strategy. The strategy is approved by the Board of Directors of Barry-Wehmiller Group Inc. The document will be periodically reviewed and any amendments will be approved by the Board of Directors. It is effective for the year ended 30 September 2020.

2. Our Strategy

2.1 Summary

The Group is committed to paying the required amount of tax required under the laws and regulations of UK tax legislation and practice. It takes a conservative approach to tax planning, and does not pursue aggressive tax planning arrangements. The Group uses third party advisors to provide advice and guidance necessary to assess tax risks and ensure its compliance with applicable laws, rules, regulations and reporting and disclosure requirements.

2.2 Tax Objectives

Approach to risk management and governance arrangements in relation to UK taxation

The Group will operate effective tax governance, understanding the tax risks in place and ensure that senior personnel with the appropriate skill and experience are involved in key tax decisions.

The Group uses third party advisors to provide advice and the guidance necessary to assess tax risks and ensure its compliance to applicable laws, rules, regulations and reporting and disclosure requirements.

The Group wants to ensure that it pays an appropriate amount of tax in relation to its commercial activities. It does not engage in aggressive tax planning arrangements, and believes that it is conservative in its approach to tax planning, applying tax rules and regulations in a way that it considers is consistent with parliament鈥檚 intention, and HMRC expectations.

The Group has a capable finance team. All staff have clear roles and responsibilities to assist in compliance with tax (and financial) requirements.

In cases involving more difficult areas of tax, advice is sought from the external professional advisors as to the appropriate application of the tax rules.

Attitude towards tax planning and level of risk it is prepared to accept

We expect to maintain a low risk rating with HMRC.

The Group takes a conservative approach to tax planning and does not pursue aggressive tax planning arrangements. Where alternatives routes exist to achieve the same commercial result the most tax efficient approach in compliance with all relevant laws shall be considered.

We seek to be efficient in our tax affairs but ensure that any planning is based on sound commercial principles. We will take advantage of the reliefs and incentives that exist but show respect for the letter of the law, as well as the intention, at all times.

The Group will use incentives and reliefs to minimise the tax costs of conducting its business activities, but will only undertake arrangements which they reasonably believe do not contradict the spirit of the law. For example, the Group will not undertake transactions for tax which are inconsistent with the underlying economic consequences or undertake marketed avoidance. The company will not establish business in tax havens.

Approach to dealing with HMRC

We will avoid unnecessary time consuming disputes wherever possible.

We are committed to working in a collaborative, transparent and proactive way with HMRC at all times. We adopt the principles of openness and transparency in our approach to dealing with HMRC and believe in engaging in full, open and early dialogue with HMRC to discuss the Group鈥檚 tax affairs. The Group is committed to making fair, accurate and timely disclosure in correspondence and returns, and respond to queries raised by HMRC in a timely manner with the aim to resolve issues quickly and efficiently, with certainty wherever possible.

Duty under Finance Act 2016

The Group considers that this publication complies with its duty under Schedule 19 Finance Act 2016.