1. Introduction

The Eisler Capital Group (“Eisler Capital”), a UK headquartered asset manager, is committed to conducting its UK tax affairs in a responsible and compliant manner. This document sets out the tax strategy for all UK companies within the Eisler Capital Group. This tax strategy document outlines our approach to tax governance, risk management, planning, and our relationship with tax authorities. It is designed to align with Paragraph 19(2) of Schedule 19 of the Finance Act 2016.

2. Governance and Management of Tax Risk

The principles and control objectives set out in this tax strategy have been reviewed and approved by the Board of Eisler Capital (UK) Ltd. The Board understands its duties in terms of tax and its wider corporate responsibilities and puts strong emphasis on meeting the objectives set out in this strategy.

Eisler Capital’s Finance Department is responsible for overseeing all aspects of tax governance and risk management. The Finance Director reports directly to the COO. A primary objective of the Finance Department is to ensure full compliance with global tax obligations and to pay the correct amount of tax to the appropriate jurisdiction, in accordance with the law, and with complete transparency.

Eisler Capital maintains a low appetite for tax risk and prioritizes success with integrity. All new business and product proposals undergo a rigorous review process by the Finance Department and approval by Senior Management to prevent contrived or artificial tax arrangements. Additionally, this review considers the potential impact on Eisler Capital’s reputation and broader governance objectives. In line with Eisler Capital’s tax strategy, the Finance Department collaborates with the wider business groups to identify, assess, monitor, and manage tax risks within the business escalating to the COO as appropriate. The Finance Department may seek external tax advice from a reputable firm of advisers in relation to any matters in which the tax treatment is potentially unclear.

3. Tax Planning

Eisler Capital supports genuine commercial activity by making use of tax incentives or opportunities within the relevant tax laws of each jurisdiction. When dealing with complex tax laws or when particular tax risks are identified, external advisers may be engaged to ensure proper interpretation and compliance.

4. Relationship with Tax Authorities

Eisler Capital is committed to establishing cooperative, professional, and transparent relationships with government tax authorities, including HMRC. We seek to resolve any uncertain material tax issues before filing tax returns whenever possible. Furthermore, we proactively disclose and discuss significant tax uncertainties with the relevant tax authority. In the unlikely event non-compliance is identified, Eisler Capital would seek to make an unprompted disclosure to the relevant tax authorities, including HMRC, on a timely and transparent basis.

5. Compliance with Paragraph 19(2), Schedule 19 of Finance Act 2016

This tax strategy is published in compliance with our duty under Paragraph 19(2), Schedule 19 of the Finance Act 2016 and is related to the accounting period ending on 31 December 2023.