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Zscaler, Inc. UK Tax Strategy Policy

The below makes publicly available Zscaler, Inc. and its subsidiaries, affiliates and related entities  (“Zscaler”) Tax Strategy Policy in accordance with Schedule 19 of the Finance Act 2016 for the UK.

Our Approach to Risk Management and Governance

Our tax function, tax governance, and tax strategy are supervised by the Vice President of Tax, with appropriate level of review by our Chief Accounting Officer, Chief Financial Officer, Chief Executive Officer, Audit Committee of the Board of Directors, and ultimately the Board of Directors.

We are committed to remain compliant with tax laws and practices in the countries where we operate. The tax team manages risks on a daily basis and includes members of appropriately qualified and experienced personnel whose knowledge is current through continued professional development.

Where there are areas of uncertainty or higher complexity in relation to a risk, advice is sought from external tax advisors to ensure that the tax issue is appropriately dealt with. However, complete ownership of the final tax position remains with Zscaler.

Our Attitude Towards Tax Planning

Zscaler manages risks to remain compliant with legal requirements and to ensure the appropriate amount of taxes are paid.

We do not engage in illegitimate or artificial tax arrangements, i.e., planning that is not underpinned by commercial and economic substance. Tax planning measures are always in line with the tax legislation with a low risk of non-acceptance by Tax Administration.  Regular guidance is also sought from external advisors where an uncertainty exists.

Our approach to tax planning is to engage with our staff and tax advisors to derive holistic planning that aligns with our business operations, enhances value, and manages tax risks.

How We Assess Tax Risk

Given the activities of Zscaler and the volume of tax obligations, tax risks will inevitably arise from time to time. We actively seek to identify, evaluate, monitor, and manage these risks to remain in line with Zscaler’s objectives and broad attitude towards any risk. 

Potential tax risks are assessed, and internal controls are implemented to mitigate the risks to an acceptable low level.

Internal control procedures and processes are subject to regular reviews, internal audits, and self-assessment programs.

Our Approach to Dealings with HMRC

We engage with HMRC with honesty, integrity, and in a transparent manner. We strive to form relationships with tax authorities in a professional and collaborative manner. 

We are committed to disclose all relevant facts and circumstances to the tax administration. In the event of a disagreement with a tax authority, we will seek to resolve any disputed matters through proactive and transparent discussion.