Air Products and Chemicals, Inc. is the ultimate parent of the Air Products group based in the United Kingdom. As a United States industrial gas company with global operations, Air Products generates a substantial amount and variety of taxes across the jurisdictions in which it operates, including (but not limited to) income taxes, stamp duties, employment taxes and indirect taxes such as value added tax.

This tax strategy document applies to Air Products Group Limited and all the UK entities within the Air Products group (the “UK Group”). The publication of this UK tax strategy statement is regarded as satisfying the requirements of Schedule 19 of Finance Act 2016.

This tax strategy document applies to all UK taxes applicable to the UK Group and is effective for the financial year ending 30 September 2024. The tax strategy statement will be reviewed annually and updated as necessary.

Approach to tax governance and risk management

Operational and governance responsibility for the execution of the UK Group’s tax strategy rests with the Vice President, Taxes, supported by a global team of tax professionals. The tax affairs of the UK Group are managed by a qualified tax team and external tax expertise is used where necessary.

The UK Group is within the scope of the UK Senior Accounting Officer (“SAO”) legislation and the SAO is responsible for ensuring the UK Group establishes and maintains appropriate accounting and tax compliance arrangements. 

Air Products complies with all relevant revenue laws, and all taxes are accounted for and paid. Procedures and controls are in place to ensure tax compliance obligations are satisfied.

Air Products maintains procedures designed to prevent the facilitation of tax evasion in accordance with Part 3 of The Criminal Finances Act 2017.

Given the scale of our business and volume of tax obligations, risks will inevitably arise from time to time in relation to the interpretation of complex tax laws and the nature of our compliance arrangements. In such circumstances, Air Products seeks to identify, evaluate, monitor and manage these risks to ensure that they remain in line with our objectives and are within materially acceptable levels. Where there is a significant uncertainty or complexity in relation to a tax risk, external advice may be sought.

Responsible attitude towards tax planning 

The UK Group does not enter into any aggressive tax planning or support the use of artificial structures that are established solely to avoid paying tax and have no business purpose. The UK Group’s tax planning is aligned with its commercial business and economic activities.

Air Products transfer pricing policy is aligned with the Organisation for Economic Co-Operation and Development (OECD) guidelines as well as the guidelines of the various jurisdictions in which Air Products operates. The prices are benchmarked, considering the functions, assets and risks in the various jurisdictions.

Air Products has a Code of Business Conduct and Ethics that applies to its employees, directors, and officers around the world. All employees must complete the Code of Conduct training and certification annually. The Code states that if someone becomes aware of anything they believe may violate a law, regulation, the Code or another Group policy, that individual should report the violation or what the individual believes or suspects is a possible violation. Reporting channels include a confidential and anonymous hotline.

Transparent approach to engaging with HMRC

The UK Group engages with His Majesty’s Revenue and Customs (“HMRC”) in an honest, respectful, transparent, and co-operative manner. The UK Group does not take positions on tax matters that may create reputational risk or jeopardise our good reputation with HMRC. We regularly meet with HMRC where we discuss tax compliance and reporting, ongoing issues and major transactions.