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Tax Policy

Skylark Group Tax Policy

Basic Principle

Based on the management philosophy of “Creating Richness with Value to Society,” our Group has set forth the mission of “To offer great-tasting food at affordable prices with good service in our comfortable restaurants to as many people as possible” in order to incorporate the purpose of “To contribute to enriching people's lives and to the advancement of society as a whole by creating the future of dining” into the action level of each and every employee.
Based on the above philosophy system, the Group has established the “Skylark Group Charter of Corporate Behavior” to be shared by all officers and employees, and is committed to complying with laws, international rules and their spirit, as well as to acting with social common sense. In the area of taxation, in order to ensure compliance with tax laws and regulations applicable in the countries and regions in which we operate, as well as with international tax laws and regulations, tax risk management and appropriate tax payment, and the development and operation of a highly transparent tax governance system to support these activities, we have established the “Skylark Group Tax Policy” and will thoroughly implement it.

  1. Compliance with Tax Laws and Regulations
    The Group has established the “Skylark Group Charter of Corporate Behavior” to be shared by all officers and employees, and is committed to complying with laws, international rules, and the spirit of such rules, as well as to acting in a socially sensible manner.
    In line with the Group's business objectives and business reality, we will conduct appropriate tax management based on our responsibilities as a taxpayer and comply with applicable laws and regulations in all countries and regions where we conduct business activities.
  2. Use of Tax Systems with Commercial Substance
    The Group will not interpret or apply laws and regulations in a manner that deviates from their intent, nor will it engage in tax reduction through intentional tax avoidance. We are committed to not using tax systems without commercial substance, and will consider using tax systems only when they have commercial significance in our business activities and a proper economic rationale exists.
  3. Tax Risk Management
    Through a correct understanding of domestic and foreign taxation systems, the Group aims to keep tax risk at an acceptably low level in order to enhance corporate value.
    For transactions with unclear tax interpretations in business activities, the department in charge of taxation will be involved at an early stage to manage tax risks by fully examining such transactions with advice from third-party tax experts and, if necessary, checking with the tax authorities.
  4. Transfer Pricing
    We regularly seek advice from outside tax specialists to examine tax risks. In particular, we have established the following system to address transfer pricing tax system and tax havens in foreign-related transactions.
    In foreign-related transactions, we comply with the laws and regulations of each country and appropriately respond to tax system revisions based on the OECD Transfer Pricing Guidelines and the BEPS Project Action Plans.
    With respect to transactions with foreign affiliates, we consider arm's length prices and allocate profits appropriately based on an analysis of the functions, assets, and risks involved in each country and among our group companies, in proportion to their contributions. In addition to complying with documentation required by laws and regulations, the Company will implement risk management based on a separately established transfer pricing risk management policy.
  5. Addressing Tax Havens
    We do not engage in tax planning with the intention of tax avoidance, such as the use of tax havens without business purpose or business reality.
    When an investment is made in a light-tax-exempt country, or when the tax rate is reduced due to a revision of laws and regulations in the country or region where the business is located, the application of the anti-tax haven taxation system is determined according to the laws and regulations of the country or region.
    As a result, if the company is subject to anti-tax haven taxation, it will file an appropriate tax return.
  6. Ensure Transparency to Stakeholders
    The Group prepares and submits country-by-country reporting items annually in accordance with Japanese tax laws, and also prepares and submits business overview reporting items in compliance with the tax laws of the countries and regions in which the Group operates.
  7. Relationship with Tax Authorities
    Through communication with domestic and foreign tax authorities, the Group will endeavor to maintain good relationships with the authorities, ensure transparency by responding appropriately and cooperatively, and promptly provide information in response to tax audits and requests by the tax authorities.
    When a problem or other issue is identified, we immediately clarify the cause of the problem and take appropriate corrective and remedial measures to prevent recurrence, except in the case of objections or lawsuits against the measures or opinions of the tax authorities.
  8. Tax Governance
    Tax-related tasks are performed by the department in charge of accounting, as defined by the segregation of duties standard. The governance structure for taxation is structured with the executive officer in charge of the Group's finances at the top, and the accounting officer reports on accounting and tax status as appropriate.
    Executive Officer in charge of Finance is responsible for establishing and maintaining the governance structure for the Group's tax compliance and risk management, and reports to the Board of Directors on the status of governance in accordance with this policy.
    In addition, issues deemed to be of high importance are submitted to the Board of Directors for decision-making. These issues are regularly reported to the Audit Committee members.

※ This policy was approved by the Group Sustainability Committee in April 2024.

April 25, 2024
Approved by Group Sustainability Committee

Tax Payments by Region (FY2023)

FY2023 
Country/
Region
Company Name Main Business Earnings Current Benefit Before Tax Income Taxes Paid Income Tax Payable Number of Persons Employed
      Millions of yen Millions of yen Millions of yen Millions of yen Person
Japan See the table below See the table below
339,993 7,908 1,480 2,034 40,171
Other See the table below See the table below 15,297 783 0 181 1,710
Amount recorded in consolidated financial statements     355,290 8,691 1,480 2,215 41,881

The above amounts are based on "Country Reporting Matters" to be submitted to the Japanese tax authorities and have no direct relation to the consolidated financial statements.

Company Name and Main Businesses

Company Name Main Business
Japan
SKYLARK HOLDINGS CO., LTD.
Skylark Restaurants Co., Ltd.
NILAX Inc.
Tomato and Associates Co., Ltd.
FLO Japon Co., Ltd.
Japan Cargo., Ltd.
Skylark D&M Co., Ltd.
 
Restaurant Business
Restaurant Business
Restaurant Business
Restaurant Business
Others
Others
Others
Other
Taiwan Skylark Co., Ltd.
SKYLARK USA INC
SKYLARK MALAYSIA SDN.BHD.
 
Restaurant Business
Restaurant Business
Restaurant Business