UK TAX STRATEGY DURING FISCAL YEAR 2025

Scope

This tax strategy was prepared in accordance with Paragraphs 19 (2) and 25 (2) of Schedule 19 of Finance Act 2016 for the financial year ending 31 December 2025 and applies - until superseded- to the entities listed below (collectively referred to as “UK Entities” or “We”):

• Aramco Overseas Company UK Limited;
• Aramco Trading Limited;
• Aramco Ventures Limited (formerly known as SAEV Europe Limited);
• Saudi Petroleum Overseas, Ltd.;
• Aramco InvestCo, LP; and
• Valvoline UK Limited.

Tax Governance 

We operate under the umbrella of Aramco’s multinational sophisticated and sizeable group tax function led by tax counsel, and tax compliance and accounting professionals who are tasked with providing responsive legal and tax advice (collectively referred to as Global Tax). 

Management of each legal entity is responsible for complying with applicable law, regulations and governance procedures.

Tax Risk Management

Our approach to management of taxes and tax risks is governed by an enterprise-wide comprehensive framework that has been implemented and operationalized.

The framework includes:

1. Tax Policy;
2. Appropriately resourced and sufficiently qualified tax function;
3. Technology solutions to support the tax functions.

We have established robust controls and procedures to ensure the accurate and timely filing of tax returns and payment of taxes. This includes a comprehensive tax governance framework, proactive identification, assessment, and management of tax risks, and ongoing review of existing and emerging tax risk areas, together with their potential business impact.

Our approach to compliance with applicable legal and tax obligations supports the strategic and commercial operations of our business.

The actions to manage each tax risk vary depending on the issues identified and the priority assigned to them. Nonetheless, the Group mitigates tax risk by ensuring that tax matters are reviewed by appropriately qualified tax professionals, supported by regional and global tax teams.
 
Attitude to tax planning and level of risk

We adopt a conservative approach to tax risk. Our approach to tax planning is focused on maintaining the highest legal and ethical standards. We comply with applicable UK tax laws and regulations and only enter into arrangements that support our organizational strategic and commercial operations.

We do not tolerate tax evasion and the facilitation of tax evasion. We assess the tax implications of new business opportunities and other transactions, ensuring that any tax outcomes are supported by genuine commercial objectives and an appropriate factual foundation.

Working with His Majesty’s Revenue and Customs (HMRC)

We are committed to complying with applicable UK tax laws and regulations and maintaining robust tax governance and administration processes. 

We seek to maintain an open, professional, and constructive relationship with HMRC, engaging with integrity, respect, and cooperation in all tax matters.