Square UK Tax Strategy

About Square

Square creates tools that help sellers start, run, and grow their businesses. Square enables sellers to accept card payments and also provides reporting and analytics, next-day settlement, and chargeback protection. Square’s point-of-sale software and other business services help sellers manage inventory, locations and employees; engage customers; and grow sales.

Square serves millions of sellers around the world. We launched in the UK in March 2017, making it easier than ever for small and medium-sized businesses to never miss a sale by card payments and enabling them to more broadly run their business. The UK marks the fifth country where Square is available, joining the U.S, Canada, Japan and Australia.

Square was founded in 2009 and is headquartered in California, where the majority of our research and development takes place. Because our products and services are created, designed and engineered in the U.S., that is where we pay most of our tax.

Scope of Policy

The tax policy below applies to the following UK subsidiaries (collectively “Square UK”) of Square, Inc. (“Square”) and has been published as required and in accordance with Schedule 19 to the Finance Act 2016.

• Squareup (UK) Ltd.
• Squareup Europe Ltd.

This tax policy applies to both direct and indirect taxes, including corporate income taxes, PAYE, and VAT.

Risk Management and Governance in Relation to UK Taxation

Square UK’s policy is to comply with all relevant rules, regulations, disclosure requirements and to pay the amounts of tax that are legally due. Square’s Chief Tax Officer, who reports to Square’s Chief Financial Officer, is ultimately responsible for Square UK’s tax strategy and policies.

Square UK has internal governance procedures set at the executive level by Square. Through people, processes, controls and systems, Square UK manages tax risks and compliance with tax laws. Where a tax risk is identified, Square UK’s governance procedures require its escalation and prompt notification to the appropriate senior personnel, including Square executives. In addition, Square UK may seek to manage tax risks that are complex or uncertain by obtaining advice from external tax advisors or by engaging directly with HMRC.

Square does not accept any form of behaviour that facilitates the evasion of tax, whether in the UK or in any other jurisdictions. Square is committed to ensuring that it has procedures in place at all times to prevent tax evasion by anyone acting on its behalf.

Attitude Towards UK Tax Planning and Level of Risk

Square UK assesses what it must do in order to remain compliant and takes appropriate steps to achieve this compliance when it enters into transactions or makes changes to its business. The same approach is taken whenever new tax legislation is introduced or HMRC changes their policies. When there is uncertainty or complexity in relation to the law or its application, Square may seek advice from external advisors. If this is insufficient to achieve certainty or to address the complexity, Square UK may engage directly with HMRC to better understand the application of the law and ensure compliance. Square UK’s tax positions and reporting reflect the business activities undertaken in the UK. Square UK does not enter into any artificial or abusive arrangements in order to reduce its liability to UK taxes.

Relationship with HMRC

Square UK is committed to ensure full compliance with all statutory obligations to tax authorities. Square UK engages with tax authorities, including HMRC, with honesty, integrity and respect. Square UK’s approach is to be transparent, and to cooperate fully with HMRC in a timely manner. Square UK discloses all relevant facts when when submitting tax computations and returns to HMRC.

This document will be periodically reviewed by the Square Corporate Tax team. It is effective for the year ending 31 December 2017 and will remain in effect until any amendments are approved by the Chief Tax Officer.