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Cooper Tire – UK Tax Strategy

Cooper Tire & Rubber Company UK Limited and its UK subsidiary companies (principally Cooper Tire & Rubber Company Europe Limited), hereinafter referred to as ‘Cooper Tire’ regard the publication of the information set out below as complying with its duty under Finance Act 2016 Schedule 19 paragraph 16 (duty to publish a tax strategy) and paragraph 20 of the same Schedule.

The following was first made available on 5 December 2018 and is in respect of the financial year ended 31 December 2018.

The sections below follow the requirements as listed in Finance Act 2016 Schedule 19 paragraph 23 and related guidance as issued by HMRC.  


Cooper Tire is fully committed to complying with UK tax legislation and to act with integrity and clarity in achieving such compliance.

We submit accurate tax returns to HMRC and make any associated tax payments on a timely basis. Our tax returns fully disclose our tax liabilities to the UK Government.

Approach to risk management and governance arrangements (in relation to UK taxation)

Day to day UK tax matters are managed by our in-house European Tax Operations Controller who reports to our European Finance Director (a member of the UK Leadership team) and also to the Cooper Tire group’s Corporate Tax Department, based in the USA. 

To the extent that Cooper Tire’s UK Leadership team does not identify such matters on its own, material or significant tax matters are proactively brought to their attention by the UK and US-based internal tax teams and the outside tax advisers that Cooper Tire engages to aid in its compliance efforts. The UK Leadership team agree on a course of action, based upon proposals made to them, and determine whether further dialogue with internal or external resources is necessary. 

Attitude towards tax planning (so far as affecting UK taxation)

Cooper Tire’s Global Code of Conduct requires all of its employees to act with integrity and in accordance with applicable legislation and ethical obligations.

The Code of Conduct can be found at: http://investors.coopertire.com/Cache/1001215869.PDF?O=PDF&T=&Y=&D=&FID=1001215869&iid=4008251

With the assistance of its internal and external tax advisers, Cooper Tire engages in tax planning as needed to ensure continued compliance and to understand the tax impact of commercial transactions evaluated and undertaken by the business.

Cooper Tire is part of a global corporate group.  The group’s Corporate Tax Department has overall responsibility for all tax compliance matters regarding group companies, including those group companies based in the UK.  For any tax planning that it undertakes, the Corporate Tax Department’s highest priority is that all group companies fully comply with applicable tax laws.

Level of risk (in relation to UK taxation) that Cooper Tire is prepared to accept

Our internal governance is not prescriptive as to the level of risk that Cooper Tire is prepared to accept. 

However we generally have a low appetite towards UK tax risk and aim for certainty in our tax filing positions. Our approach to tax risk is not influenced by stakeholders.

Our business involves the international movement of goods, services and people and as a result we consider these areas as giving rise to our key tax risks. In order to mitigate these risks we seek external tax advice from international accounting firms when the appropriate scale and depth of expertise does not exist internally, or when a third party expert opinion is otherwise desired. 

Benchmarking studies are also undertaken to identify arm’s length pricing in order to comply with UK tax legislation and international guidance.

Approach of Cooper Tire towards its dealings with HMRC

We make every possible effort to ensure full compliance with our UK statutory tax filing obligations and to respond in a timely manner to any requests from HMRC for further information.

Cooper Tire has an open, proactive working relationship with HMRC. We liaise with the relevant HMRC contact or specialist depending on the nature of the issue under discussion. Due to our current size we do not, at present, have an HMRC Customer Relationship Manager (CRM).

We will seek to obtain clarity from HMRC in real time, if there are any areas of uncertainty impacting us regarding existing or recently enacted tax legislation or in relation to any relevant HMRC guidance.