- Sonic Healthcare Limited (‘Sonic Healthcare’) is a company incorporated in Australia and is listed on the Australian Securities Exchange. Sonic Healthcare is one of the world’s leading providers of medical diagnostic services. Sonic Healthcare provides highly specialised pathology/clinical laboratory and diagnostic imaging services to clinicians (GPs and specialists), hospitals, community health services, and their patients.
- Sonic Healthcare operates in a number of countries through its subsidiary entities, where our business activities lead to a variety of taxes being levied. Our approach to tax is aligned with our formal Board Tax Policy in relation to tax governance, which has been approved by the Sonic Healthcare Board of Directors. The principles of this Policy are set-out in the Sonic Healthcare Taxation Governance document (dated 1 December 2021) which can be found on Sonic Healthcare's website.
- As referred to in Sonic Healthcare’s Taxation Governance document, our approach to taxation aligns with our general business strategy, Code of Conduct and our Core Values. It also recognises that a large proportion of our revenue comes from governments and therefore it would be inconsistent with the priorities of our shareholders to risk our reputation with governments by adopting aggressive or non-compliant tax practices.
- The UK operations of Sonic Healthcare are carried out by The Doctors Laboratory Limited and its associated UK companies and controlling interests in its Limited Liability Partnerships (LLPs) (“UK Group”). The UK Group act autonomously in the capacity of their trade, however corporate governance and oversight of tax risk is managed centrally by Sonic Healthcare.
How we manage tax risk
- Our UK Group Chief Financial Officer has overall control and responsibility for the UK Group tax position and has the appropriate level of oversight to ensure that the ultimate decisions made regarding tax matters are consistent with Sonic Healthcare’s approach to tax risk. The UK Group Chief Financial Officer communicates directly with Sonic Healthcare in Australia and the UK Board, who are kept informed regarding the UK Group’s tax position and tax matters.
- Our internal risk management procedures operate to ensure that we identify, monitor and manage tax risks which are relevant to each of our UK business units.
- We employ specific finance personnel in the UK to support the UK Group Chief Financial Officer. The UK Head of Finance, UK Group Financial Controller and senior finance personnel have sound knowledge of the UK tax laws which are relevant to our UK Group’s activities. It is their responsibility for ensuring that UK tax legislation is adhered to and that all tax compliance obligations are met. The UK Group Chief Financial Officer oversees this to ensure these responsibilities are being carried out effectively.
- In addition to this, our external tax advisers provide us with support of specific tax advice and regular updates regarding upcoming changes to the UK tax legislation.
Our attitude to tax planning
- We seek to operate in a tax efficient manner, making use of all relevant exemptions and incentives put in place by the UK tax authorities and OECD principles. Where they exist we seek to apply them in the manner intended by the UK tax authorities and in accordance with the relevant legislation.
- Our tax planning strategy is not aggressive and we do not engage in artificial tax arrangements.
- Where applicable, clearances are sought prior to engaging in any tax planning activities to ensure the UK Group is compliant.
- Our tax planning adheres to Sonic Healthcare’s Taxation Governance document referred to above. External tax planning advice may be sought to understand the tax impact of any commercial changes to the UK Group or assessing the impact of upcoming changes to the UK tax legislation.
Our tax risks
- Our level of risk is in line with Sonic Healthcare’s Taxation Governance approach, and we do not enter into transactions or structures without commercial substance. Oversight of the UK Group is provided by the UK Group Chief Financial Officer, who ensures that Sonic Healthcare’s Taxation Governance is implemented consistently in the UK.
- The UK Board is responsible for approving our tax policies and delegates tax risk management to the UK Group Chief Financial Officer who is supported by specific finance personnel in the UK. Our team in the UK is appropriately qualified and we invest in continued professional development and external advisors to support the UK Group.
- Transactions between our group companies are minimal, however where these do occur, the UK Group aims to conduct them on an arm’s length basis and in accordance with current OECD principles.
Our relationship with the tax authorities
- We work collaboratively with our tax advisers (who act as agents, on our behalf with the UK tax authorities) to ensure that we meet all compliance obligations and that we pay the correct amount of tax.
- We seek to operate an honest and transparent relationship with HMRC, providing the necessary disclosure required. We seek approval/clarification where necessary from HMRC.
- 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.
In making this tax strategy available the UK Group of The Doctors Laboratory Limited, its associated entities and controlling interests in its LLPs (Sonic Healthcare Holding Company, HSL(Nominee) Limited, TDL Genetics Limited, NWLHT Facilities LLP, NWLHT Analytical LLP, Health Services Laboratories LLP, HSL (FM) LLP, HSL (Analytics) LLP, HSL Pathology LLP, Labex Analytics LLP, Labex Facilities LLP ; are fulfilling its responsibilities under paragraph 22 (2) of Schedule 19 FA 2016 for the year ended 30 June 2022.