Susquehanna International Securities Limited (UK Branch) Tax Strategy

The Susquehanna International Group of Companies (“SIG”) is a world-leading technology-empowered financial trading group. Founded in 1987, SIG has grown from an options trading firm on the floor of the Philadelphia Stock Exchange to one of the world’s largest privately held financial institutions. Today, with offices around the world, SIG trades almost every major financial product and is recognised for its disciplined and quantitative trading approach and its leading-edge trading systems.

SIG’s presence in Ireland was established in 1999 and includes affiliates such as Susquehanna International Securities Limited (“SIS”), a MiFID authorised investment firm. SIS is a member of all the major European exchanges and is a leading market maker in terms of volumes traded and products covered in the listed options, futures and ETF space.

SIS pays corporate taxes, employment related taxes, stamp duties and financial transaction taxes, VAT and other applicable taxes. The taxes paid represent a significant contribution to the economy and SIS is committed to complying with tax laws and having open and constructive relationships with tax authorities (the “Revenue Authorities”).

The UK branch of SIS (“SIS UK Branch”) was established in 2016 and provides sales support services to the operations of SIS in Ireland (“SIS Ireland”). However, SIS Ireland retains responsibility for all trading activity and has the financial capacity and the skilled trading staff necessary to manage and control the risks relating to trading and market making.

The sales support services provided by SIS UK Branch include engaging with existing and potential counterparties of SIS Ireland with the aim of raising the profile of the liquidity provision capability of SIS Ireland. The UK branch is a small component of the overall SIS business.

Tax Risk

SIS UK Branch has exposure to UK corporate taxes and employment related taxes. The branch supplies services only to its head office and is therefore not registered for VAT. Due to the relatively small scale and the nature of the activities of the branch, its exposure to tax is limited.

Management of Tax Risk

SIS identifies, assesses, and manages tax risks and accounts appropriately for taxes. SIS employs risk management measures which include use of a dedicated in-house accountant, access to SIG’s tax department, and the engagement of external advisers as appropriate to assist in management of tax risk.

Governance

The board of directors of SIS (the “Board”) has ultimate responsibility for the management of the affairs of the company including formation of strategy and policies. In order to appropriately manage SIS’s affairs, the Board established a management committee (the “Management Committee”) and delegated certain powers to the Management Committee regarding the management and oversight of SIS. The head of tax function in SIS reports to the Management Committee and is responsible for ensuring that policies and procedures are in place, maintained, and used consistently for supporting the management of tax risk and ensuring compliance with tax law. The head of tax function in SIS is also tasked with ensuring that the tax team has the necessary skills and experience to manage tax risk and ensure tax compliance. In short, SIS takes many steps to minimize governance risk.

Tax Planning

SIS engages in tax planning in order to support its business, appropriately reflect commercial activity, and adhere to relevant tax law. Transactions between group companies are conducted on an arm’s-length basis and in accordance with current principles of the Organization for Economic Cooperation and Development. External advisors are engaged as required to assist with tax planning.

Workings with Revenue Authorities

SIS seeks to build and maintain a constructive relationship with Revenue Authorities. Where possible, SIS engages with Revenue Authorities in order to achieve certainty and agreement on the tax treatment of particular events.