In accordance with UK legislations, Schedule 19 of Finance Act 2016, the company is publishing its tax strategy for the Year Ended 31st December 2023, which will be refreshed annually. As the head company of the UK group, we confirm that this strategy will apply to the following UK companies for all UK taxes:

• Fresenius Medical Care (Holdings) Limited
• Fresenius Medical Care (UK) Limited
• Fresenius Medical Care Renal Services Limited
• Fresenius Medical Care Renal Services (UK) Limited
• Fresenius Medical Care Renal Services (IDC) Limited
• Fresenius Medical Care Renal Services (SS) Limited
• Fresenius Medical Care Renal Services (UAE) Limited
• Optimal Renal Care Limited
• NxStage Medical UK Limited

This strategy is aligned with the principles and tax compliance culture set forth in Fresenius Medical Care’s overall tax strategy. We confirm that the ‘Group FME Tax Policy’ is adhered to by the UK group.

We aim for our tax affairs to be compliant with UK tax legislation and the Board of Directors in the UK are committed to the delivery of tax compliance. The Board has delegated responsibility for the Tax Strategy and Compliance to one member of the Board, namely the Finance Business Partner, who updates the Board on key tax issues.

The UK group actively reviews and updates its tax risk management and governance processes, including how tax risk is identified, assessed and mitigated.

We employ the services of a professional tax advisor to prepare our Corporate Tax Computations and, Returns and to provide other services including tax technical updates and flagging new legislation to help reduce the risk of non-compliance. We also ensure that we employ appropriately qualified and experienced staff to prepare and submit relevant returns, for example VAT and PAYE and who undertake the relevant training required to satisfy the CPE requirements of their professional bodies and keep up to date with new and emerging legislation and guidance.

Our appetite for tax risk is low and the UK Board of Directors sees compliance with tax legislation as key to managing our tax risk by using principles of reasonableness.

Due to the size and complexity of the business there is an inherent degree of tax risk. We recognise that eliminating tax risk entirely is impossible, but we aim to manage our tax risk as far as practically possible.

In areas of uncertainty where tax risk arises from the complexity of tax legislation and differences in interpretation, we will seek appropriate external advice before engaging with HMRC.

Our approach is to aim to be compliant and understand our responsibilities with regard to tax and we will claim legitimate tax incentives, exemptions and reliefs offered by the UK Government to all taxpayers.

We will consider a range of tax outcomes based on the underlying commercial intention of any business activity or transaction that supports our business activities and the UK group’s code of conduct, rather than looking for ways to aggressively avoid the payment of tax. We seek to balance the shareholders’ interest of managing business expenses, which include taxation, with ensuring that any arrangements comply with current UK tax legislation.

We have a responsibility to minimise our tax risk and our exposure to negative publicity through non-compliance.

Intercompany transactions are conducted on arm’s length principles following international standards and UK legislation.

We seek to ensure that our engagement with HMRC is professional, open and honest by having a co-operative and proactive working relationship with them. We also aim to undertake our filing requirements in a timely manner, by meeting relevant filing and payment deadlines for taxes that the company pays.

This strategy was reviewed and approved by the Board of Directors.