UK Tax Strategy

Introduction

The Nintendo Group is primarily engaged in the home entertainment business (“Dedicated video game platforms”). Hardware and software for both handheld systems and home consoles are developed, manufactured and distributed by Nintendo Co., Ltd. in Japan and by its subsidiaries and associates in other overseas markets.

In the UK Nintendo operates through a branch Nintendo of Europe SE (UK Branch) with its headquarters based in Frankfurt am Main, Germany.

Year Ended 31 March 2024

This tax strategy applies to the UK operations of Nintendo of Europe SE and is in accordance with paragraph 22(2) of Schedule 19 to the Finance Act 2016. References to ‘tax’ include taxes and duties as set out in paragraph 15(1) of Schedule 19.

It will be reviewed and updated annually.

Nintendo’s approach to corporate governance and risk management in relation to UK taxation

As an international group, Nintendo identifies and is required to manage various risks in the different markets in which it operates. These will include tax risks and possible uncertainties in those markets and could include UK tax risk.

Our tax affairs are managed in a way which takes into account the group’s corporate reputation and are in line with Nintendo’s overall high standards of governance, corporate social responsibility (CSR), code of conduct and values.

As an international group, Nintendo’s Transfer Pricing arrangements are in line with arm's length principles and OECD guidelines.

The group is principally subject to Corporation Tax, Income Tax/PAYE, NIC and VAT in the UK. Processes have been designed to ensure all returns are prepared accurately, reviewed by competent officials and submitted on a timely basis, thus following the group’s overall attitude to compliance requirements.

In order to ensure compliance UK tax returns are subject to senior management review within the finance department and approval from the company’s chief executive officer prior to submission to HMRC.

Nintendo employs both in-house tax professionals and external tax advisors, who support Nintendo’s business by ensuring tax strategy and tax compliance are aligned with the strategy and operations of all business segments. Tax professionals in the corporate entities are dedicated to specific business segments, geographical areas or competence areas for both direct and indirect taxes as necessary. Accordingly, taxes are monitored and considered by management of each local jurisdiction as well as the parent company as part of the overall review and approvals process.

Nintendo’s attitude towards tax planning

Nintendo does not engage in tax planning in the UK or other jurisdictions that is not aligned with the group’s strategy and business operations. The company preserves its reputation by complying fully with tax laws in all jurisdictions where it operates with the highest integrity. Nintendo believes that it interprets UK tax law in a reasonable way and which reflects the commercial background behind any significant transaction. The company seeks regular external advice to ensure that it is fully compliant with applicable laws.

Where available Nintendo seeks to apply any relevant UK tax reliefs and allowances in the manner intended by HMRC and statute, first taking external professional advice where necessary. At the same time the group seeks to retain competitiveness by monitoring tax cost worldwide, reducing tax risk and avoiding double taxation while complying fully with all tax laws.

Level of risk in relation to UK taxation that Nintendo may accept

Nintendo’s appetite for tax risk is low and we only structure our affairs based on sound commercial principles and in accordance with the group’s corporate internal control regulations. Artificial tax arrangements are never considered as part of the group’s tax strategy. The company focuses its efforts on minimizing the risk of double taxation in those markets in which it operates including the UK.

Nintendo engages tax professionals to ensure that risks are fully assessed. Where uncertainty exists the company seeks additional external advice, to ensure all tax positions taken are reasonable under the law. In doing so, tax risk is assessed specifically case by case.

Nintendo’s approach towards its dealings with HMRC

Nintendo strives to be transparent and cooperative in its interaction with all tax authorities and is committed to an open, honest working relationship with HMRC, which includes supplying all relevant information that may be required by HMRC to review tax risks. The company also concludes advance agreements and requests clearances for significant transactions where appropriate. Additional disclosure is made where requested or on submission of returns where there has been an interpretation of tax law or where a treatment on unclear items is proposed.

Approved: March 2024