Lugano UK

Lugano Diamonds UK, Ltd

Tax Strategy

Lugano Diamonds UK, Ltd (“Lugano UK”) is a wholly owned subsidiary of Lugano Diamonds and Jewelry, Inc (“Lugano”), headquartered in the US. The following sets out Lugano UK’s tax strategy and approach and has been approved by the Board of Directors. Lugano UK regards this publication as compliant with its duties under Part 2 of Schedule 19 Finance Act 2016 for the year ending December 31, 2023.

This tax strategy and approach will be periodically reviewed as appropriate and any changes updated once approved by the Board.

UK Tax Strategy and Approach

Lugano UK’s tax strategy supports the Lugano global tax strategy of minimizing UK tax risk by:

Observing all applicable laws, rules, regulations and reporting and disclosure requirements

Meeting all legal requirements and filing the appropriate returns

Paying the correct amount of tax in the appropriate jurisdictions in a timely manner

Considering the Lugano brand, reputation as well as our corporate and social responsibilities

Tax planning is never undertaken as an isolated exercise. Lugano only undertakes tax planning that is aligned with its commercial and economic activities, and which has commercial substance. We would not undertake tax planning that was not within the tax law and spirit of the legislation of the countries in which we operate. Lugano UK does not enter into contrived or artificial tax arrangements intended for the avoidance of tax.

Tax Risk Management

Lugano’s global finance team, which includes the Lugano Chief Financial Officer, are responsible for management of Lugano UK’s tax risk. This management is based on adherence to Lugano policies and procedures, strong internal controls and advice and counsel from UK based tax, accounting, and legal advisors where appropriate.

Lugano UK does not accept a level of risk which would potentially result in reputational harm, or which may adversely affect Lugano UK’s relationship with H M Revenue & Customs.

Approach to Dealing with HM Revenue & Customs

Lugano UK is committed to acting in an open, honest and transparent manner when dealing with HM Revenue & Customs office. Lugano UK strives to minimize tax risk and any disputes with HM Revenue & Customs by complying with relevant filing, reporting and disclosure requirements.

Date Published: 31 December, 2023