INTRODUCTION
The Policy is aimed to establish the key principles for identifying, assessing and managing tax risks within AEON Credit Service (M) Berhad (“ACSM”) and its subsidiaries (“the Group”). It provides a structured approach to ensure that all tax affairs are managed responsibly, transparently and in compliance with applicable tax laws and regulations.
The Policy has been approved by the Board of Directors sets out clear roles, responsibilities, and internal control measures to promote accountability and integrity in tax management.
SCOPE
- The policy set out in this document shall be complied by all staff based on the responsibilities identified. Non-compliance with the requirements set out in this document shall be deemed as breach of discipline that can lead up to dismissal.
- Strategic Planning & Reporting Group being the owner of the document is responsible to ensure this policy is updated and revised accordingly when there is any change in regulations or business process.
OUR POLICY
Approach to Tax Strategy and Governance
The Board of Directors (“the Board”) holds ultimate responsibility for overseeing ACSM’s tax governance and overall tax affairs. The Board delegates the day-to-day management of tax matters including the identification and management of tax risks to the Chief Financial Officer (“CFO”) under the oversight of ACSM’s Audit Committee (“AC”) and Board Risk Committee (“BRC”). The CFO, supported by the Strategic Planning and Reporting Group, is responsible for effective management of the Group’s tax function. These responsibilities include ensuring regulatory tax compliance and maintaining a robust framework for managing tax risks and exposures.
The Group’s Tax Code of Conduct is guided by the following principles:
- Fulfil tax obligations appropriately, including timely and accurate registration, filing of tax returns and payment of taxes in a timely manner, and maintenance of proper documentation and tax reporting
- Zero tolerance for tax evasion
- Foster open and collaborative professional relationships with relevant tax authorities
- Ensure tax implications are comprehensively assessed and applied to all transactions where appropriate, particularly new and significant transactions
- Apply the arm’s length principle in intra-group transactions
Approach to Tax Planning
- To ensure the Group remains compliant with tax laws and regulations, the Group is consistently considering the potential tax implications and consult third party advisors before implementing any strategic business plans, day to day business activities, capital investment programme or changes in corporate structure and business model.
- The Group will only engage in tax planning or utilise tax incentive that supports a genuine business purpose and in line with the intended objectives of the Government that introduced the incentives.
- Apply due diligence professional care including seeking written opinion from third party advisors and ruling/ confirmation from tax authorities where necessary to ensure that position taken is supportable and defendable in a tax audit.
- The Group engages external tax consultant to conduct periodic tax health checks as an independent assessment of the Group’s overall tax compliance status, internal processes and potential exposure areas separate from advisory work on specific transactions.
Management of Tax Risks
- Any changes in relevant tax laws and practices are monitored through regular updates from external tax advisors and participation in seminars or trainings to enhance tax awareness and compliance.
- Depending on the degree of risks and / or nature of the transactions involved, tax actions or decisions will be referred to the Board/ AC/ BRC/ Management for approval and guidance where required.
- Tax risks shall first be identified and registered with the Risk Management Department and are subject to internal control testing. The Group will seek professional advice from external advisors when there is a need for more insights or better clarity on specific complex tax technical matters before any further action is taken to ensure that the Group remain compliant with the relevant tax laws and regulations.
- Checklist and controls have been implemented through quarter submission to Operation Risk Department to manage tax risk proactively and to achieve overall tax compliance.
- Material tax issues, if any, must immediately be escalated and reported to Management, and, where necessary, further escalated to Board Risk Committee and the Board.
- Performing of internal tax briefings training upon changes in tax legislation and any tax implications on new and significant transactions.
- Digital transformation initiatives are continuously applied to core functions that have been identified by management as having higher risk exposure and significant transaction volumes.
Approach towards Transfer Pricing
The Group is committed to meet the arm’s length principle of determination of prices for transactions between related parties, to ensure the payment of taxes occur in the appropriate jurisdiction and/ or business line. Transfer pricing related decisions will be referred to relevant Management for approval and guidance.
Relationship with Tax Authorities
The Group is committed to fostering a cooperative and constructive relationship with tax authorities by upholding the following principles:
- To deal with tax authorities and other relevant bodies in a collaborative courteous and timely manner
- Complying with legal obligations, including compliance, reporting and payment responsibilities
- To provide response to any queries and information requests on a timely manner
- To resolve issue(s), if any, with the tax authorities amicably, transparently and professionally
