OUR APPROACH TO TAX

Introduction

Royal Caribbean Group (“RCCL”) is a publicly traded cruise line company with worldwide operations, which delivers world-class and memorable vacations, responsibility, to guest around the world., RCCL operates three brands: Royal Caribbean International, Celebrity Cruises, and Silversea Cruises. In addition, we have joint venture interest in TUI Cruises and Hapag-Lloyd cruises. In the United Kingdom (“UK”), Silversea Cruises business presence is composed of two UK legal entities: Silversea Cruises (Europe), Ltd. and Silversea (UK), Ltd. referred to as (“SS UK”).

Our Tax Principles

SS UK is committed to being a responsible global citizen. We follow global rules, regulations, and guidelines in accordance with our Code of Business Conduct and Ethics and except our advisors, employees, and other parties to do the same.

Our approach to tax is summarized by our tax principles, which are approved by the Board of Directors and are closely aligned with the group’s core values and business strategy. In particular, SS UK will continue to:

• Comply with all relevant laws and regulations.
• Consider tax in all major or complex business decisions.
• Meet all legal requirements and make all appropriate tax returns and tax payments.
• Comply with appropriate tax controls and processes and ensure there is sufficient Board oversight into this compliance where appropriate.
• Utilize incentives and reliefs to minimize business tax costs in a manner which is consistent with the UK government’s policy objectives.
  

Our tax risk management and governance

SS UK is risk-averse, and we adopt a conservative approach as regards to tax matters.

To ensure that we effectively comply with our UK tax requirements, SS UK rely on a set of processes and controls that will regularly be reviewed and maintained for the purposes of Senior Accounting Officer (SAO)¹ compliance.

RCCL is committed to complying with all relevant laws and regulations in all jurisdictions where the group operates and with SS UK will be no different. Tax Management is performed through the RCCL Corporate Tax Department and in constant collaboration with the SS UK business and finance department to provide the guidance and advice needed to ensure compliance with tax laws and regulations.

At a global level, RCCL’s corporate tax department is overseen by the RCCL Audit Committee of the Board of Directors. The Vice President of Global Tax is responsible for implementing our approach to tax. The team is responsible for ensuring that policies and procedures that support the approach are in place and that the tax group has appropriate skills and experience required.

Our approach to tax planning

Tax planning opportunities must have a clear commercial rationale and be approved by the Board and are evaluated with current tax rules in mind while taking the legislator’s intention into account. Where there is uncertainty as to the application or interpretation of the tax laws, appropriate written advice evidencing the facts, risks and conclusions will be obtained from third party advisers to support the decision-making process. SS UK does not engage in aggressive tax planning and does not enter into transactions for the sole purpose of gaining a tax benefit.

Our relationship with HMRC

SS UK is committed to engaging in a transparent and proactive manner with HMRC. The company’s UK tax affairs, past and proposed operations are discussed in an annual meeting with HMRC. Furthermore, the company maintains an ongoing communication with HMRC to discuss and conclude on areas the application of legislation to our facts is uncertain, ensure compliance with UK tax laws and regulations, communicating changes to our business and tax affairs in advance to HMRC.