Synergy Hire Limited – Strategy for Tax Management

Introduction

Hitachi Construction Machinery Group (“HCM”) operates globally across a range of business areas, primarily around the manufacture and sale of heavy construction equipment and specialised technologies. As a result, the Group is exposed to a variety of risks, including those arising from economic conditions, industry-specific factors and operational activities. This applies equally to its operations in the UK.

The UK tax environment continues to evolve, with increasing emphasis on transparency, governance and compliance. UK legislation, including the Senior Accounting Officer (“SAO”) regime and the requirement to publish a tax strategy under Schedule 19 of the Finance Act 2016, places obligations on qualifying businesses to clearly articulate their approach to tax.

HCM is committed to maintaining high standards of tax governance and compliance. We aim to act responsibly and transparently in all tax matters and to meet both the letter and spirit of applicable tax laws.

Scope

This strategy applies to those UK entities within the HCM Group required to comply with Schedule 19 of the Finance Act 2016 and sets out the UK tax strategy for Synergy Hire Limited for the financial year 1 April 2025 to 31 March 2026.

UK Tax Strategy

Our tax strategy is aligned with the Group’s wider business objectives and is focused on ensuring that tax risks are managed appropriately while supporting sustainable commercial outcomes. This strategy covers the following areas:

  • Approach to risk management and governance
  • Attitude towards tax planning
  • Level of tax risk the Group is prepared to accept
  • Approach towards HM Revenue & Customs (“HMRC”)
  1. Approach to Risk Management and Governance

We are committed to maintaining a robust tax governance framework supported by effective systems, processes and internal controls. Responsibility for tax matters rests with the Chief Financial Officer, supported by appropriately qualified finance personnel and, where necessary, external professional advisers.

We operate a structured tax control framework designed to:

  • Ensure compliance with all relevant tax obligations
  • Identify, assess and manage tax risks on a timely basis
  • Maintain appropriate documentation and audit trails

Controls are subject to regular monitoring and review. As part of this, we undertake internal control testing, including JSOX compliance processes, to ensure that key controls operate effectively. In addition, we comply with the Senior Accounting Officer (SAO) requirements, ensuring that appropriate tax accounting arrangements are in place and maintained.

Where significant or complex tax matters arise, we may obtain professional advice as well as escalating these matters (as appropriate) within the Group, including to HCM Group Head Office tax function, to ensure consistent and informed decision-making.

  1. Attitude to Tax Planning

We seek to comply fully with the tax laws and regulations of the United Kingdom, as well as applicable international standards. We follow both the letter and the spirit of the law in all tax matters. Tax considerations are aligned with genuine commercial activity, and tax planning is undertaken only where it supports commercial objectives. When entering into significant transactions:

  • The tax implications are carefully evaluated
  • External advice is obtained where appropriate
  • Decisions are based on a reasonable interpretation of applicable legislation

We do not engage in aggressive tax planning and do not enter into arrangements that lack commercial substance or are intended to achieve tax outcomes contrary to the intent of legislation.

  1. Level of Tax Risk

We maintain a low tolerance for tax risk and seek to minimise uncertainty in our tax affairs and do not take positions that are inconsistent with the clear intent of tax legislation. The objective is to ensure that tax risks are identified early, managed effectively and maintained within acceptable levels. Where there is uncertainty or complexity:

  • Appropriate analysis is undertaken
  • External professional advice may be sought
  • Matters may be discussed with HMRC where appropriate
  1. Approach Towards HMRC

We are committed to maintaining an open, transparent and cooperative relationship with HMRC. Where appropriate, we seek to engage proactively with HMRC, particularly in relation to complex or uncertain tax matters, with the aim of resolving issues collaboratively and efficiently. We will:

  • Submit accurate and timely tax returns and disclosures
  • Responds promptly to HMRC enquiries
  • Provides information in a clear and transparent manner

Compliance

We keep up to date with relevant tax legislation and ensure ongoing compliance with all applicable requirements.

This tax strategy is published in accordance with paragraph 16(2) of Schedule 19 to the Finance Act 2016 and applies to the financial year 1 April 2025 to 31 March 2026.