UNITY UK TAX STRATEGY

Unity is publishing this tax strategy for financial years beginning with the year ended 31 December 2022 and for all subsequent financial years, in accordance with the provisions of paragraphs 19(2) and 22(2) of Schedule 19 of the UK Finance Act 2016. This tax strategy applies to Unity’s UK companies and includes application of UK tax laws.

Tax risk management

The responsibility for the management of our tax risks is ultimately borne by the Chief Financial Officer (CFO), overseen by Unity’s Board of Directors and Audit Committee. Day-to-day implementation of the tax strategy is performed by the VP Tax, supported by a team of qualified in-house tax professionals based in key countries.

The tax regimes under which we operate as a multinational company are complex and may be subject to significant change. Changes in tax laws or tax rulings, or changes in interpretations of existing laws, could materially affect our financial position and results of operations. Certain risks may arise because the application of tax laws are often complex and uncertain. As such, we’ve established policies and procedures designed to ensure the consistency of our tax filings and positions globally, as well as to ensure we comply with our wider tax compliance obligations on a timely basis. These processes are subject to our internal audit and review process, as well as external validation through our work with external advisors. These policies help ensure we comply with applicable laws and regulations in the UK and globally.

Unity regularly utilizes external tax consultants for professional advice to support the tax department in managing tax compliance and mitigating tax risks.

Unity’s attitude to tax planning

Unity’s tax team is involved when making commercial decisions and discussing the wider business strategy. They are responsible for ensuring that Unity operates in a cost-efficient manner that supports the commercial objectives and legal obligations of the business. This includes adding value through identifying opportunities for seeking reliefs, incentives and credits, and, where legally possible, to eliminate the risk of double taxation. The tax team partners with cross functional teams to ensure that they react to local nuances to mitigate local risk and support compliance with all tax laws and regulations. This includes understanding the role of the local entities to ensure they are in line with the OECD’s arm’s length standard in relation to transfer pricing wherever we operate. Unity does not undertake planning that is artificial in nature and seeks to align the local tax strategy to the commercial and economic substance of the business.

Unity’s level of risk acceptance

Unity does not engage in aggressive tax planning and does not have a prescriptive level of tax risk. Tax risks are proactively monitored and managed by the tax department.

Working with HMRC

As with all global tax authorities, we strive to engage fully with HMRC in a cooperative and compliant manner. We aim to reply to all information requests in a timely and transparent manner. We are committed to resolving any disagreements through open discussions. We involve advisors to assist us in communication with HMRC where required.