Capital One (Europe) plc - Tax Strategy – Statement Capital One (Europe) plc ("Capital One UK") is required to annually publish its Tax Strategy in accordance with Section 161 and Section 19(2) Schedule 19 Finance Act 2016. This document sets out Capital One UK's Tax Strategy for the year ending 31 December 2018. Capital One UK seeks to pay all taxes, including corporation tax, VAT and employment taxes, on a timely basis, meet all reporting requirements and, adopts an open approach with tax authorities, principally HM Revenue & Customs. The UK Business's Tax Strategy is adopted by the UK Board under guidance from Capital One's Global Tax Department and has full regard to the UK's risk appetite. In particular, Capital One UK will: Comply with all relevant tax laws and disclosure requirements; Deal professionally and transparently with all tax authorities; Only undertake tax planning based on the economic and commercial activities of the business; Maintain accounting systems and controls as required to support the tax compliance obligations. Approach to tax risk management and governance Capital One UK is subject to all policies and procedures of the Global Corporation. This is equally true in the area of taxation. Monthly updates are provided by Global Tax to the UK CFO who is a board member of the UK business. Procedures require that major changes to operations or activities are signed off by Global Tax through UK Finance representations. Attitude to Tax Planning Tax planning is undertaken having regard to the commercial and economic activity of the business. Capital One UK does not seek to structure transactions in ways that give results inconsistent with the underlying economic reality. Capital One UK undertakes tax planning that is both within the letter and the spirit of tax law. Tax matters are handled by Global Tax's UK in-house tax team which is staffed by suitably qualified and experienced tax professionals. Occasionally and where appropriate, external technical advice is sought to challenge or to support technical interpretations of transactions. This enables business decisions to be taken with full knowledge of likely tax results. Level of Risk The Company at all times seeks to limit the tax complexity of the business. Capital One UK works to maintain its low risk status as assessed by HMRC. Approach to dealing with HMRC Capital One UK engages openly with HMRC based on mutual trust and respect. The Company raises all materially uncertain positions on a real-time basis to limit the uncertainty and minimize tax risk.