Ingram Micro Asia Pte. Ltd. (the “Company") Tax Governance Policy
Introduction
At Ingram Micro, the six Tenets of Our Success – Results, Courage, Integrity, Responsibility, Imagination, and Talent – reflect who we are and how we operate. Integrity is at the root of our unfailing commitment to maintaining the highest ethical standards. Complying with laws and regulations that govern our company is one critical step. Even more important is that we do the right thing, the right way, every day. Our partners, associates and investors expect nothing less.
Compliance with Tax Laws
Our approach to taxes is grounded by the following tax governance policies.
The Company strives to act as a responsible corporate taxpayer in compliance with applicable tax law and regulations, seeking to minimise the risk of uncertainty or disputes in tax matters.
The Company's tax compliance strategy is:
- to comply with the Singapore tax rules and regulation to the best of its ability and when in doubt, consult with the external tax advisors;
- to ensure taxes are paid on time and in accordance with the applicable tax rules; and
- to prepare and retain the documentation required by the tax law.
The Company adopts a proactive approach in updating its tax policies and procedures to keep pace with evolving tax regulations and industry practices.
When new tax laws are introduced and their application is unclear, the Company consults with external tax advisors. Where appropriate, it may also seek clarification or an advance ruling from the relevant tax authorities to ensure its tax positions are consistent with the intent of the law.
The Company will ensure that any tax planning and business strategies pursued are in line with the spirit and intent of the tax laws and regulations and are duly supported by the commercial and economic rationale.
Governance Structure for Managing Tax Risks
The Board of Directors in Singapore is ultimately accountable for the Company’s tax governance policy. The responsibility for executing the tax strategy and maintaining the internal tax control framework is delegated to senior management within the Company's Finance / Tax Teams.
Appropriately qualified tax professionals are employed within the tax / finance function and supported by the US Head Office tax team.
The Company's appetite for tax risk is low and as part of the risk management process, qualified external tax advisors are engaged to ensure risk level is within the Company's acceptable threshold and to prevent the emergence of unforeseen risks / errors.
The Company’s tax principles, governance and control framework and tax risk management controls are regularly reviewed. The Company ensures that all relevant stakeholders are appropriately informed, with reference to qualitative and quantitative thresholds.
Documented processes and controls relating to Singapore tax compliance are subject to periodic reviews and are updated as needed to reflect business and legislative changes.
Relationship with Tax Authorities
The Company seeks to comply with its Singapore tax filing, tax reporting and tax payment obligations in line with statutory timelines. An important part of the tax strategy is the commitment of building a constructive and positive relationship with the IRAS based on good faith and transparency in pursuit of long-term collaborative relationship.
The Company regularly reviews both internal and external tax risks associated with its business operations. Where needed, the Company also considers the opportunity to voluntary disclose tax errors under the Voluntary Disclosure Programme and ensures that appropriate controls will be put in place to prevent future recurrence of the errors.
Where tax enquiries or audits are raised by IRAS, the Company adopts a proactive approach and will co-operate to provide information to the IRAS, with assistance from qualified external tax advisors, with the aim to resolve the queries promptly and accurately.