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Darktrace's Comprehensive Public Tax Strategy

Introduction

Darktrace, a pioneering cyber security technology company founded in 2013 by mathematicians and cyber defence experts from the University of Cambridge, has established a robust tax strategy aimed at ensuring transparency and compliance with local tax requirements. This strategy covers various tax areas such as corporate income taxes, indirect taxes like VAT, employment taxes including PAYE and National Insurance, and other relevant tax matters. Reviewed annually, this strategy focuses on conducting all tax affairs in a transparent manner that adheres to local tax regulations.

Governance

Darktrace's Group Tax Department, based in Cambridge, handles the implementation of the tax strategy approved by the Board of Directors. Reporting to the Group CFO, the Finance Director oversees all tax activities across the Group entities. The Group Tax Department is responsible for providing guidance and support on tax matters, ensuring compliance with tax regulations, and managing tax obligations. Additionally, the department develops, maintains, and reviews tax procedures, controls, and policies to support effective tax management.

Attitude to Tax Risk and Tax Planning

As a global organization, Darktrace recognizes the tax risks posed by complex tax legislation and the international tax environment. While understanding that risks cannot be entirely eliminated, Darktrace focuses on minimizing them through robust compliance processes and engagement with external advisors when necessary. The company avoids high-risk or aggressive tax planning and instead engages in tax planning based on genuine commercial activities. Darktrace complies with applicable tax regulations, utilizes statutory reliefs like R&D tax relief, and follows arm's length principles globally to ensure tax efficiency and compliance.

Relationship with HMRC and Other Tax Authorities

Darktrace values open and transparent relationships with fiscal authorities such as HMRC and other global tax bodies. The company maintains proactive communication with tax authorities, promptly provides requested information, and engages in dialogue to address tax matters collaboratively. Darktrace promptly discloses any inadvertent errors in tax submissions to tax authorities once identified, showcasing its commitment to integrity in global tax reporting.

Versioning

This policy, currently at Version 3 (last amended on July 1, 2024), undergoes annual reviews and updates. Any revisions are documented in the version notes for transparency. The previous version (Version 2) was published on February 8, 2023, demonstrating Darktrace's commitment to regularly updating its tax strategy to align with evolving tax requirements.

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