Tax Strategy

NLF Tax Strategy

The following Tax Strategy has been approved by the Board of the Nuclear Liabilities Fund Limited (‘NLF’) and outlines how NLF seeks to manage tax affairs, mitigate current and emerging tax risks and have an open and transparent relationship with His Majesty’s Revenue and Customs (‘HMRC’) in respect of UK tax obligations.

NLF is committed to full compliance with all statutory obligations and full disclosure to tax authorities. The tax affairs are managed taking into account NLF’s need to safeguard its reputation with stakeholders and its high standards of governance.

Governance and approach to risk management

The board of directors of NLF (the ‘Board’) has ultimate responsibility for NLF’s tax affairs, it reviews and approves the Tax Strategy on an annual basis. There are also regular tax updates to the Audit and Risk Committee.

The Board has delegated the day-to-day responsibility for the management of taxes to specialist tax advisers. The outsourced provider comprises a team of professionals who are equipped with the appropriate knowledge, skills and capabilities to manage NLF’s tax affairs.

The Board, with support from its specialist tax and investment advisers, ensures that NLF’s tax strategy is one of the factors considered in investment decisions.

Attitude to tax planning

NLF does not engage in artificial tax arrangements without business or commercial substance. Our tax advisers work with us to ensure that the appropriate tax analysis and considerations are undertaken for material decisions. Where relevant, NLF utilises legitimate tax incentives and reliefs offered by tax authorities.

Level of risk that NLF is prepared to accept

NLF seeks to comply fully with its regulatory obligations by observing all applicable laws, rules, regulations and reporting and disclosure requirements thereby ensuring the correct amount of tax is paid. Where there is significant uncertainty or complexity in relation to tax risk, advice will be sought. Where appropriate, advance clearance will be sought from HMRC. This aligns with our low appetite for tax risk and ensures the tax arrangements are consistent with a prudent approach.

Approach to dealings with HMRC

NLF seeks to have a transparent and constructive relationship with HMRC. When submitting tax computations and returns to HMRC, NLF seeks to disclose all relevant facts. NLF is within the Senior Accounting Officer (‘SAO’) regime and as such the SAO provides annual certificates to HMRC in relation to appropriate tax accounting arrangements.

UK legislation

This Tax Strategy is in relation to the accounting period ended 31 March 2027 and is published in accordance with the requirements of paragraph 22(2) of Schedule 19 to the Finance Act 2016 and addresses the matters set out in paragraph 23 of that Schedule.

This strategy has been reviewed and approved by the Board of Directors of Nuclear Liabilities Fund Limited on 23 September 2026.