Tax Strategy for the United Kingdom

1   Tax Strategy for the United Kingdom

2   Scope

This document sets out Evercore’s approach and strategy for handling the tax affairs and managing the tax risks for the year ending 31 December 2023 for the entities listed below (each an “Evercore UK entity”, and together “Evercore UK”).

Evercore UK regards the publication of this tax strategy as complying with section 161 and paragraphs 19(2), 22(2) and 25 of Schedule 19 to the Finance Act 2016. This tax strategy applies to each Evercore UK entity and applicable UK taxes.

This strategy is updated annually, and ratified annually by the boards of directors of Evercore UK (or the executive committee of Evercore Partners International LLP in the case of Evercore Partners International LLP).

3   Introduction

Evercore is a global independent investment banking advisory firm dedicated to the highest calibre of professionalism. The Evercore UK entities are majority owned by Evercore Inc., a US publicly traded company listed on the New York Stock Exchange. Evercore UK’s tax strategy is based on established policies, procedures and controls to ensure compliance with all applicable UK tax legislation. Evercore UK is committed to ensuring that it pays the appropriate amount of UK tax, and that its UK tax returns and payments are accurate and made on time.

4      Risk management and governance arrangements

Evercore promotes a culture of risk management, and implements good risk management procedures. Evercore UK identifies, assesses, mitigates and manages risks, including tax risks, which is vital to its business strategy. All business strategies, including tax, are led and overseen by the senior management of Evercore, and ultimately overseen in the UK by the boards of the Evercore UK entities (or the executive committee of Evercore Partners International LLP in the case of Evercore Partners International LLP).

Evercore UK’s internal finance and tax teams, which regularly report to senior management, have established processes compliant with Sarbanes-Oxley Act (SOX), FCA requirements, and HMRC tax requirements. The head of tax for Evercore UK is responsible for the day-to-day management of UK tax compliance, planning and reporting.

Evercore UK engages external advisers to provide additional assistance with tax compliance, including for supervisory review of Evercore UK’s business risk strategies, and to review its internal processes and procedures. Evercore UK also seeks tax advice from external tax advisors where the tax treatment of transactions is complex, unclear or uncertain under UK tax law.

Evercore does not tolerate tax evasion or the facilitation of tax evasion. Following the introduction of the Corporate Criminal Offence of Failure to Prevent the Facilitation of Tax Evasion legislation, which came into force on 30 September 2017 as part of the Criminal Finances Act 2017, Evercore UK has implemented appropriate procedures and controls to prevent any person acting on its behalf from facilitating tax evasion.

5   Tax planning

Tax consequences of transactions are taken into account as part of Evercore’s overall decision-making process, but transactions are driven by commercial rather than tax mitigation motives. Evercore does not implement or utilise any aggressive or marketed tax avoidance strategies or artificial structures. Evercore may take advantage of available tax reliefs or well established and accepted arrangements where this is provided for by law. All transactions have an underlying commercial substance and any related tax planning arrangements are in line with its tax strategy and low tax risk tolerance. In accordance with OECD guidelines, all intercompany transactions with Evercore UK entities are conducted on arm’s length principles.

6   Tax risk appetite

Evercore has a low tolerance for tax and regulatory compliance risk. Evercore UK’s low risk tolerance is set by senior management and is influenced by its reputation as a leading independent investment banking advisory firm, in which context tax or regulatory failings could have a material adverse effect on its reputation and relationship with HMRC and key stakeholders (including shareholders, employees and clients) and its business. Evercore UK aims to lower risk and uncertainty by seeking appropriate external advice and engaging directly with regulatory bodies worldwide, including HMRC.

Evercore UK’s governance framework operates to ensure compliance with UK tax laws and regulations. This also ensures that Evercore UK identifies, assesses and mitigates UK tax risks effectively.

7   Working with HMRC

Evercore UK is committed to complying with all UK statutory obligations, filing requirements and/or tax disclosures required by HMRC. Evercore UK’s relationship with HMRC is guided by its core values and high standards of business conduct. Evercore UK works collaboratively wherever possible with HMRC to answer queries, resolve disputes and obtain certainty in relation to UK tax risk, the UK tax treatment of proposed business transactions and the interpretation of UK tax law.

8   Entities covered by this tax strategy

This tax strategy applies to Evercore Partners International LLP, Evercore ISI International Limited and the UK subgroup comprising: Evercore Holdings Limited, Evercore Partners Limited and Evercore Group Services Limited.

Date of Publication: 31 December 2023