UK Tax Strategy
INTRODUCTION
Integra is a world leader in medical technology focused on limiting uncertainty for surgeons so they can concentrate on providing the best care for their patients. Integra provides customers with clinically relevant, innovative and cost-effective products that improve the quality of life for patients. We focus on cranial procedures, the repair and reconstruction of soft tissue, and instruments for use in surgery. Integra manufactures many of its products in plants located in the United States, Canada, Puerto Rico, France, Germany, Ireland, and Switzerland. We sell our products globally through a combination of direct sales organizations and third-party distributors and our business activities lead to a variety of taxes being generated in a number of countries. Our approach to tax is aligned with our longstanding policy, to conduct our business ethically, honestly and lawfully. This is set out in our Standards of Business Conduct and Ethics, which applies equally to each of our subsidiaries and business units worldwide. In addition, our global finance team works together so that corporate governance and oversight of tax risk are managed centrally. We strive to successfully execute our business objectives while complying with all applicable local, national and international tax laws and regulations of the countries in which we operate.
HOW WE MANAGE TAX RISK
In 2018 our current Senior Vice President, Finance and Principal Accounting Officer (“SVP Finance”) assumed primary control and responsibility for the affiliated group’s tax position and has the appropriate level of oversight to ensure that the ultimate decisions made regarding tax matters are consistent with Integra’s approach to tax risk. The SVP Finance communicates directly with Integra’s Chief Financial Officer and, if appropriate, with the Board, to ensure that they are kept informed regarding Integra’s tax positions and associated tax matters. Our internal risk management procedures operate to ensure that we identify and monitor results on a quarterly basis. Part of this review is to identify and manage tax risks which are relevant to each of our global business units. Any material risks identified are escalated, external tax advice is obtained if necessary and relevant disclosures are made. We employ experienced and qualified tax and finance personnel who have sound knowledge of the tax laws and regulations that are relevant to Integra’s business activities. It is their responsibility for ensuring that tax laws and regulations are adhered to and that all tax compliance obligations are timely met. The SVP Finance is regularly updated to ensure that these responsibilities are being met. In addition to this, where appropriate, our external tax advisors provide us with specific tax advice and regular updates regarding proposed changes to local tax legislation.
OUR ATTITUDE TO TAX PLANNING
We seek to operate in the most tax efficient manner, making use of all relevant tax exemptions and incentives put in place by relevant tax authorities and OECD principles. Where they exist, we seek to apply them in the manner intended, in accordance with our Standards of Business Conduct and Ethics. Our tax planning strategy is aligned with our Standards of Business Conduct and Ethics and where appropriate, advice and rulings are sought to ensure that we are compliant with all tax laws and regulations.
OUR TAX RISKS
Oversight of our group is provided by the SVP Finance, who is responsible for ensuring that Integra’s tax strategy is implemented consistently across the US, UK and other countries. Our teams are appropriately qualified, and we invest in continued professional development and external advisors to support us. We consider the tax risks for our business to be relatively low and will seek advice and guidance from the wider group and external advisors on issues such as transfer pricing.
OUR RELATIONSHIP WITH THE TAX AUTHORITIES
We work collaboratively with our tax advisors to ensure that we meet all compliance obligations and that we pay the appropriate amount of tax. We support the G20’s multilateral moves towards greater transparency in order to increase understanding of tax systems and build public trust. Therefore, in accordance with OECD principles, we provide the necessary information to the tax authorities in which we operate to allow them to understand the operations and tax risk profile of our business units. Aligned to our Standards of Business Conduct and Ethics, we seek to operate an honest and transparent relationship with international tax authorities, including HMRC, providing the necessary disclosure required and seeking approval/clarification where necessary. In making this tax strategy available the UK group is fulfilling its responsibilities under paragraph 16(2) Schedule 19 FA 2016 for the year ended 31 December 2025.