Canada Life UK tax strategy

2023 UK tax strategy

We are a responsible taxpayer, aiming to comply with the tax rules of each country in which we operate. We
act with integrity, keeping our customers and stakeholders at the heart of what we do. This is reflected in our focus on tax compliance, our low tax risk appetite and open relationship with HMRC. We aim to comply with the letter and spirit of the law. Our governance and tax risk management processes are consistent with our overall risk management framework. In the UK, our tax strategy sets out our approach to tax management and compliance as it applies across the business, as summarised below.

Governance and risk management

As part of our overall risk management and control processes, we seek to manage our tax risks and ensure:

• all appropriate tax returns are filed in accordance with UK tax laws and regulations;
• UK tax information recorded in financial statements and regulatory returns is accurate;
• uncertainties in interpretation of UK tax law are identified and managed to mitigate financial or
  reputational risk; and
• relevant boards of directors approve material tax risk judgements.

We recognise that tax is an important feature of our business, affecting our main products and services as well as being levied on the profits we make from running our business and on returns we deliver to customers. Our approach to tax should be and is no different to our overall approach to risk management.

Responsibility for compliance with the UK Tax Strategy is delivered through oversight across all UK taxes by
the UK Tax Director, with support from the UK and Group tax and finance functions. The Canada Life tax team supports our business operations with UK tax footprints, providing advice and compliance support services, managing relationships with tax authorities and assisting with tax and financial reporting obligations. Business heads with UK operations are responsible for identifying, managing and monitoring tax risk within their processes, as they are for any operational risk and have assurance procedures to evidence this. These are reviewed by our internal audit and risk functions.

Assessment of acceptable tax risk

Our long-term business objectives are to ensure obligations to customers continue to be met now and into
the future without accepting significant tax risk. This requires that risks, including tax risks, are assessed and managed effectively.

We have a low appetite for UK tax risk from our business activities. We aim to take a consistent approach using the same parameters to assess and manage tax risk in situations where an element of tax risk is maintained in accordance with our risk management framework.

We would not pursue an interpretation of the tax legislation which is incompatible with our overall attitude to tax risk management and only enter into transactions with a commercial purpose.

Attitude to tax planning

We will actively engage with legislators, tax authorities, representative bodies and other relevant third parties to inform and promote a sustainable tax environment that is in the best interests of our stakeholders. We seek to organise the UK tax affairs of group companies to meet the commercial objectives of the business in a tax-efficient manner. We strive to comply with applicable UK tax laws, regulations and rules, self-assessing and reporting all UK taxes where a tax liability is identified. We will take external tax advice on material commercial transactions where we believe that judgements on tax uncertainty are required.

Working with tax authorities

Our relationship with HMRC is one we seek to maintain and build on, characterised by open and transparent
communication. We have a proactive working relationship, formalised through an annual HMRC risk
assessment of our tax profile.

Integrity and consistency are central to the management of taxes, ensuring our obligations to our
stakeholders are met in a tax-efficient manner, underpinned by a robust approach to tax risk management. We aim to comply with the spirit and letter of the law on all tax-related matters.

The UK entities to which this strategy applies are the UK incorporated or UK branches of non-UK incorporated 51% subsidiaries listed in the “Group Undertakings” note to the published financial statements of The Canada Life Group (U.K.) Limited, available on the Companies House website, and to Canada Life Finance (UK) Limited, The Canada Life Assurance Company UK Branch and Empower Finance UK 2021 Limited.

We regard the publication of this tax strategy as complying with the duty under paragraph 16 (2) of Schedule 19 of the Finance Act 2016 to publish the group tax strategy in the current financial year.