Wise Group Tax Strategy

Approved by the Board of Directors of Wise Plc on the 6th March 2023.

Introduction

At Wise, our mission is to improve fairness and transparency in the financial services industry. Our approach to tax is designed to support this.

We operate policies and governance procedures that ensure we comply with tax laws in every territory we do business, and are committed to transparent and constructive relationships with all relevant tax authorities.

This tax strategy sets out our general approach to tax across all entities within the Wise Group. It is intended to meet the requirements set out in paragraph 16 (2) Schedule 19 of the Finance Act 2016.

Taxes we incur

Our business activities are subject to a significant level of taxation, through a variety of taxes, across numerous jurisdictions. Where applicable, we pay or incur:

• corporate income taxes;
• payroll tax and social security on employee salaries;
• irrecoverable VAT on certain costs;
• customs duties; and
• other business taxes.

Our governance structure

The Wise Plc. Board of Directors has ultimate responsibility for the Group tax strategy, and approves it on an annual basis. Executive responsibility for tax is delegated to the CFO. In turn, the CFO delegates day-to-day responsibility to the Director of Finance, supported by a global tax team. The Director of Finance gives periodic updates to the Board of Directors, including through its committees, on material tax matters such as risks, costs and changes.

Our approach to managing tax risks

We manage risks and costs in a way that is consistent with our mission, the applicable regulatory requirements, and the long-term interests of our shareholders. We also consider strategic, operational, and reputational factors.

As a listed and highly regulated business, we comply with all laws, rules, and regulations, and meet our tax compliance responsibilities in every jurisdiction where we’re subject to taxation. We have robust policies and compliance processes that ensure the integrity of our tax returns, and we make timely, accurate tax payments. We work with external tax professionals where necessary, and make sure that our tax team has the necessary training and experience. The tax team monitors the growth and direction of the business, hires new personnel and invests in automation accordingly to ensure the team is scalable and able to manage our tax position appropriately.

In every jurisdiction, we review our approach to tax periodically, considering any changes. These could include, but aren’t limited to changes in:

• the general business and regulatory environment;
• national, local and foreign tax laws and regulations;
• emerging business and tax risks; and
• guidelines and recommendations arising from tax and other authorities.

Our tax processes are subject to the same robust internal controls, assurance, and external audit as the rest of our business.

Wise has a zero tolerance approach to tax evasion and does not provide services with the aim of facilitating tax evasion in the UK or any other jurisdiction. We maintain procedures and controls which are designed to prevent the facilitation of tax evasion.

Tax planning

We pay an appropriate amount of tax in countries where value is created through the normal course of commercial activity, and we avoid contrived or abnormal tax structures. We balance this with a responsibility to both our customers and shareholders to structure our affairs in an efficient way. As such, we may make use of tax incentives or opportunities for tax efficiencies where these:

• are aligned with the intended policy objectives of the governments that introduced the incentives;
• are not considered to carry a reputational risk with any stakeholders, including tax authorities; and
• are aligned with our business and operational objectives.

The level of risk we are prepared to accept

We value our reputation and our integrity. As such, we make appropriate tax decisions that minimise tax risks and avoid jeopardising our licences.

Our processes, policies, and governance structure aim to ensure we comply with tax laws and regulations, in all the territories where we are subject to taxation. They are designed to identify and mitigate material tax risks. Tax risk and uncertainty could arise from ambiguous laws and regulations, as well as from differences in interpretation. Where possible, we seek assurance by consulting with local tax advisors and experts. If necessary, we inform senior management of any applicable tax risks, for consideration alongside our business strategy and goals.

Our relationship with tax authorities

We maintain professional and transparent relationships with tax and regulatory authorities, including Her Majesty’s Revenue and Customs.

We also proactively engage with regulatory bodies and governments on proposed changes to tax legislation. We do this both directly, and through representative bodies. Where applicable, we give tax authorities access to information that demonstrates the integrity of our tax processes, our returns, and our payments.

This is intended to assist in our compliance with tax obligations, and help reduce our level of tax risk throughout our business.