UK Tax Strategy

The WorldFirst Group is committed to compliance and taking a responsible attitude to arranging our tax affairs in line with WorldFirst values.

Specifically, in accordance with Schedule 19, Finance Act 2016, we set out below the tax strategy on behalf of WFUK for the year ended on 31 December 2023.

Business structure

WorldFirst, launched in 2004, offers foreign exchange currency solutions, electronic money and cross border payment services to commercial customers.

WorldFirst UK Limited (“WFUK” or “we”) is a limited company incorporated in UK. It has operating subsidiaries based in Netherlands, Australia, Singapore and Japan.

On 13th February 2019, WorldFirst UK Limited and its subsidiaries was acquired by Alipay (Hong Kong) Holding Limited, an affiliate of Ant Small and Micro Financial Services Group Co. Ltd (Group).

WFUK operates the business in accordance with strategies and goals set by the Group and our tax strategy is aligned to these business activities.

This tax strategy applies to WorldFirst UK Limited and its subsidiaries as a sub-group of the Group.

Our tax strategy is implemented through policies to effectively manage tax reporting and compliance in jurisdictions where we operate, and to effectively manage risks related to tax issues. To that end, we have established a tax policy to cover:

• Commitment to compliance
• Responsible attitude towards arranging our tax affairs
• Effective risk management
• Constructive approach to engaging with Tax Authorities
• Board ownership and oversight

Managing tax risk

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 law and nature of our compliance arrangements. We will actively seek to identify, evaluate, monitor and manage these risks and where there is significant uncertainty or complexity in relation to a risk, external advice will be sought, particularly in relation to international tax obligations.

The UK tax team identifies the types of tax risk that could arise. The inherent impact of these risks is then identified by considering frequency, financial size, reputational impact, legal & regulatory impact and impact on customer service. This is consistent with the Group Risk Assessment Methodology which covers all risks within the business. This produces an overall risk rating. The mitigation/controls for each of these risks is then identified and the residual impact of the risk after the application of the control or mitigation is quantified. The business endeavours to keep all tax risk as below medium risk and this is reviewed and updated every six months by the Group Risk team and any high-level risks are reported to Audit & Risk Committee and Risk Management Committee.

Attitude to tax planning

In structuring our commercial activities, we will consider – among other factors – the tax laws, rules and regulations of the jurisdictions in which we operate, with a view to maximising value on a sustainable basis. Any structuring that is undertaken will have commercial and economic substance and will have full regard to the potential impact on our reputation and broader goals. We will not put in place any arrangements that are contrived or artificial or put in place solely to reduce or avoid tax. External advice is sought to clarify an area of uncertainty or complexity.

Level of business risk

In line with our parent company, we have a low appetite for tax risk. Levels of tax risk are reviewed and monitored by the Group Risk team as described above.

How our business works with tax authorities

We will engage with tax authorities with honesty, integrity, respect and fairness and in a spirit of co-operative compliance. Wherever possible, we will seek to resolve issues through active and transparent discussions on a timely basis, to minimise tax risk and to reduce uncertainty. We are committed to compliance with tax laws, rules and regulations and practice in all the jurisdictions in which we operate. This means paying the right amount of tax in the right place at the right time. It involves disclosing all relevant facts and circumstances to the tax authorities and claiming reliefs and incentives where available. Day to day management of our tax affairs is the responsibility of the Head of Tax based in London with support from external advisors and the Group tax team based in London and Hangzhou. The CFO reports to the CEO, the Audit and Risk Committee and the Board on tax affairs and risks during the year.

Governance

The tax policy and strategy are aligned with WorldFirst values and is approved and owned by the Executive and overseen by the Board of WFUK. This statement, which will be reviewed and updated annually, was approved by the Board of Directors of World First UK Limited.