At Autodesk, we strive to conduct our business with the highest degree of honesty. We are committed to doing business ethically and this commitment as set out in our Code of Business Conduct. Everyone at Autodesk is expected to adhere to the legal obligations relating to their work and conduct themselves with integrity in all business transactions.

Based on an understanding of the needs of our stakeholders and in line with our Code of Business Conduct we have established the following principles which set out Autodesk’s tax strategy that applies to all our entities and notably to our UK entities.

Compliance

Autodesk is committed to the highest standards of corporate ethics and diligent compliance with financial accounting and reporting rules. Accordingly, we are committed to compliance to tax law in all the territories in which we operate, including the UK. Our Code of Business Conduct requires all our staff to act honestly and ethically with government officials, and to adhere to the laws and regulations of the countries in which we operate.

Tax compliance for Autodesk means paying the right amount of tax in the right place at the right time. Autodesk’s policy is to provide full, fair, accurate, timely and understandable disclosure in reports and documents and involves disclosing all relevant facts and circumstances to the tax authorities, including HMRC.

Autodesk regularly seeks advice from tax advisors to ensure compliance with applicable tax laws, rules and regulations. In addition, the Finance team is staffed with qualified individuals and training is carried out for all staff who manage matters which have tax implications.

 

Planning

In structuring our commercial activities, Autodesk considers the tax laws of the countries within which we operate with a view to maximising value on a sustainable basis for our shareholders.

Any tax planning undertaken by Autodesk will have commercial and economic substance and consider the potential impact on our reputation and broader goals.

Autodesk will not undertake planning that is contrived or artificial and we also will seek to claim reliefs and incentives where allowable.

Autodesk conducts transactions between group companies on an arm’s length-basis and in accordance with current OECD principles.

 

Tax risk management

Autodesk’s policy with respect to its tax affairs is to comply with all relevant laws, regulations and disclosure requirements. We proactively seek to identify, evaluate, manage and monitor tax risks in line with our Code of Business Conduct.

We have a tax risk matrix in place which documents our tax risks and the associated controls in place to mitigate these risks, it is the responsibility of the Finance Department to manage the tax risk matrix.

We maintain internal procedural documents to support our tax control framework and these are embedded into the global SOX framework. These internal control processes seek to ensure reported information is filed in a timely manner and provides reasonable assurance regarding reliability.

It is the responsibility of the Finance Department to proactively manage our internal controls system, monitor compliance with corporate financial policies and ensure that our practices are in line with applicable laws and regulations. The Finance Department reviews on a periodic basis our tax performance to ensure appropriate governance and oversight of tax risks.

 

Governance with respect to tax matters

Ultimate responsibility for Autodesk’s strategy rests with the Autodesk Board of Directors (Board).

The Audit Committee is responsible for reviewing and monitoring the integrity of Autodesk’s financial reporting system, internal controls, and risks associated with Autodesk's financial reporting, accounting and auditing matters, including those relating to tax matters.

Executive management for tax matters is overseen by the Board to the Chief Financial Officer (CFO).

Day to day management of Autodesk’s tax affairs is overseen by the VP of Tax, who reports to the CFO. The VP of Tax leads the tax team, staffed with qualified individuals.

Throughout the year, the VP of Tax reports to the CFO, the Audit Committee and the Board on Autodesk’s tax affairs and risks.

 

Relationship with HMRC

In line with our Code of Business Conduct we engage with tax authorities in a direct, clear and ethical manner. Autodesk is committed to maintaining a transparent and trusted relationship with all tax authorities, including HMRC.

Autodesk seeks to maintain a proactive and transparent discussion with tax authorities, including but not limited to making fair, accurate and timely disclosures in tax returns, responding to HMRC queries in a timely manner and ensuring that transactions are structured in a way that is consistent with tax laws.

The publication of our tax strategy statement is regarded as complying with Part 2 of Schedule 19 of the 2016 Finance Act.