Policy valid from: 1 October 2026

Policy valid to: 30 September 2027

Company: Frasers Property Limited

Company Registration No. 196300440G

1 Background

Frasers Property Limited (“Frasers Property”) is a full-fledged international real estate company and one of Singapore’s top property companies. As a group, Frasers Property invests in, develops and manages properties globally in markets such as Singapore, Australia, China, Europe and the United Kingdom (“UK”), etc.

In the UK, Frasers Property invests in and develops properties as well as owns and/or operates serviced apartments and hotels. This tax strategy applies to all UK subsidiaries of Frasers Property (“UK subsidiaries”) in accordance with paragraphs 16 and 19 of Schedule 19 to the Finance Act 2016. 

2 UK subsidiaries’ tax governance policy

The UK subsidiaries’ tax governance policy sets out its tax strategy as follows:

• To adopt tax positions which are consistent with what the board of the respective UK subsidiaries (“Board”) has authorised;
• To fully comply with all prevailing tax related statutory obligations in the UK;
• To pay/account for appropriate amount of tax in the UK;
• To manage tax affairs in such a way which upholds UK subsidiaries’ reputation as responsible corporate citizens with high standards of governance;
• To foster good relationships with His Majesty’s Revenue and Customs (“HMRC”).

The Board along with the appropriate Executive Committee of Frasers Property, oversee and monitor to ensure that effective governance processes and appropriate risk management frameworks are in place to comply with the prevailing UK tax legislations. They also ensure that tax strategy is one of the key considerations in all potential investments and significant business decisions taken in respect of the group’s operations in the UK.

The UK subsidiaries’ day-to-day tax affairs are managed by the finance team, which includes tax specialists, based in the UK, with support from the corporate finance and tax teams based in Singapore as well as external tax consultants in the UK.

Tax risk management

The UK subsidiaries seek to mitigate tax risks arising from its operations by:

• applying care to its processes which could materially affect its compliance with its tax obligations;
• ensuring appropriate training is provided to staff who manages matters which may have tax implications;
• appointing reputable accounting firms as tax agents to assist with the UK tax compliance matters;
• seeking advice and/or assistance on any non-routine transactions from external tax consultants where appropriate.

Attitude towards tax planning and level of risk

The UK subsidiaries’ attitude towards tax planning is every transaction has to be driven by business considerations/objectives and supported by genuine commercial activities. The UK subsidiaries are committed to ensure that none of the non-routine transactions or arrangements is undertaken solely for tax purposes. Within the commercial parameters, the UK subsidiaries will seek to maximise tax efficiencies through the use of available tax reliefs, incentives and/or exemptions which are in line with the spirit of the relevant tax legislations.

We are not prescriptive in terms of the level of acceptable risk, however at all times, the UK subsidiaries will seek to fully comply with their statutory obligations and manage their tax affairs in a way consistent with that of any responsible corporate citizen. For any non-routine transactions, the UK subsidiaries will seek to identify the associated tax risks and take appropriate mitigating actions, having regard to the materiality of risks.  We therefore consider that we have a low tax risk appetite.

Relationship with HMRC

In terms of dealings with HMRC, the UK subsidiaries will seek to maintain an honest and transparent relationship with the authorities. The UK subsidiaries will seek to engage and discuss with HMRC on any potential tax issues arising from any significant transactions and/or changes in their business.

The UK subsidiaries will also seek to ensure that all tax returns submitted are prepared in accordance with the prevailing legislations and contained the relevant facts in order to allow a proper tax assessment. Any inadvertent errors in the tax submissions will be fully disclosed to HMRC as soon as reasonably practicable after they are discovered.