FORD UK TAX STRATEGY

In accordance with Paragraph 16(2), Schedule 19, Finance Act 2016, Ford sets out below its group tax strategy for all Ford UK companies within the UK sub-group headed by Ford Britain Holdings Limited. The companies within this sub-group are listed at Appendix 1.

All other UK companies within the wider Ford group have adopted the same tax strategy and are covered by this document, with the exception of FCE Bank plc and FCLH Limited, which publish their own tax strategies. These companies are listed at Appendix 2.

Unless otherwise stated, references to ‘Ford’ or ‘the Group’ mean all UK companies within the Ford global group, with the exception of FCE Bank plc and FCLH Limited.

This strategy applies from the date of publication until it is superseded.

Risk Management and Governance Arrangements in relation to UK tax

Tax policy ultimately resides with the global group’s Board of Directors. The Directors of each Ford legal entity also have a duty to ensure that risk is managed and that appropriate governance procedures are in place for their respective entities. To ensure that these duties are fulfilled a number of arrangements exist. These include:

  • Taking decisions at an appropriate level, as governed by the global Ford group’s authorities in relation to tax matters.
  • Regular reporting of tax matters to the global group’s Board of Directors, Audit Committee and the Directors of UK legal entities.
  • Quarterly formal certification procedures including the identification, evaluation, monitoring and reporting of tax issues and risks.
  • Complying with internal control procedures and processes, which are subject to regular reviews, internal audits and self-assessment programs.
  • Seeking and documenting external advice to support tax decisions.
  • Regular reviews of how business and legislative changes may impact tax risks and controls and ensuring that staff have the appropriate skills and training to manage those risks and comply with all relevant tax legislation.
  • Implementing Ford’s core ethical behaviours and values.

Attitude of the group to tax planning (so far as affecting UK taxation)

Ford will not engage in tax planning or utilise tax incentives or reliefs, other than where such actions are permitted by law and support genuine commercial aims. Where commercial activities and transactions may be structured in ways that have different outcomes for tax purposes, Ford may structure those actions in a way which legitimately provides the most advantageous outcome. If there is any doubt as to whether the structure of the commercial actions and the tax results might be contrary to the intentions of Parliament or perceived to conflict with the spirit of the law then Ford will evaluate the actions through its internal tax governance arrangements and, where appropriate, discuss the matter openly with HMRC.

The level of risk in relation to UK taxation that the group is prepared to accept

Ford’s aim is to minimise the level of risk in relation to UK taxation at all times. The Group is not prepared to accept a level of risk that exposes it to reputational harm or which could adversely impact its relationship with HMRC. However, given the scale of Ford’s business and the complexity of tax legislation, it is inevitable that tax risks will arise. To ensure that the level of risk is kept as low as possible, several risk management policies and governance arrangements are in place, including controls specifically relating to tax that must be adhered to for all tax types.

The approach of the group towards its dealings with HMRC

Ford’s approach to dealing with HMRC is to maintain an open, professional and transparent relationship in relation to tax planning, compliance, strategy, risks and significant transactions. Ford commits to make full and accurate disclosures in tax returns and in correspondence with HMRC. If inadvertent errors or misstatements occur in tax filings or disclosures, Ford will communicate these to HMRC as soon as reasonably possible and review the causal factors to mitigate the risk of re-occurrence. The Group shall co-operate with HMRC at all times and deal with issues in a timely and collaborative manner.

Ford shall comply with its legal obligations and interpret legislation in a reasonable way that is aligned with the intentions of Parliament. Where genuine differences of opinion occur on the application of tax law, Ford will first seek to resolve these with HMRC through open dialogue and with reference to the relevant legislation and case law.

Criminal Finances Act 2017 – Failure to prevent the facilitation of tax evasion

Ford does not accept or condone any form of tax evasion or the facilitation of such tax evasion. To this end, Ford has ensured that suitable procedures are in place to prevent or minimize the risk of its employees, agents, suppliers or other third parties associated with Ford facilitating tax evasion as reflected in the Criminal Finances Act 2017. Ford will undertake, and periodically refresh, a risk-based assessment of its business activities to identify such risks and ensure that the procedures put in place are, and continue to be, adequate. Ford continues to regularly communicate its policy and senior management’s commitment to this issue and adequate training has been provided.

International Tax Matters (so far as affecting UK taxation)

International tax matters, such as the taxation of cross-border intercompany transactions and the OECD’s Base Erosion and Profit Shifting (BEPs) 2.0 initiative, are areas of taxation that have recently been receiving much global attention. In relation to the taxation of cross-border intercompany transactions (transfer pricing), Ford commits to undertake its intercompany transactions on an arm’s length basis in compliance with relevant UK tax legislation and OECD principles. In addition, Ford prepares appropriate transfer pricing documentation covering all its material intercompany transactions in accordance with the OECD’s transfer pricing documentation requirements and UK legislative provisions. Ford is also committed to ensuring that it complies with the requirements of the OECD BEPS Pillar Two initiative on global minimum taxation (as enacted in the UK) which seek to ensure that large multi-national enterprises pay a minimum effective tax in each jurisdiction in which they operate.

Appendix 1

The companies within the UK sub-group headed by Ford Britain Holdings Limited and covered by this Tax Strategy are:

  • Ford Britain Holdings Limited
  • Ford Digital Limited
  • Ford Technologies Limited
  • Ford Motor Company Limited
  • Ford Halewood Transmissions Limited
  • Ford International Liquidity Management Limited
  • Ford Retail Group Limited
  • Ford Retail Limited
  • Ford Pension Scheme for Senior Staff Trustees limited
  • Ford Pension Fund Trustees Limited
  • Ford Salaried Pension Fund Trustees Limited
  • Wheels Common Investment Fund Trustees Limited
  • Ford Pension Fund Investment Management Limited
  • Ford Senior Staff Escrow Trustee Limited
  • Standard Leasing Limited

Appendix 2

The other UK companies within the global Ford group of companies covered by this Tax Strategy are:

  • Ford VH Limited
  • Ford JL Limited
  • Ford Smart Mobility UK Limited
  • Ford Motor International Holdings Limited
  • SNTNL UK Limited

Date Published: 10/3/2026