Group taxation strategy

1. Introduction

The following tax strategy sets out the basic position of the Apollo Heights Ltd group of companies (Apollo Heights Ltd) in relation to taxation.

In the strategic direction of the family business, the sustainable prosperity of the company takes precedence over growth. Entrepreneurial thinking and employee autonomy, as well as constant improvement and future-oriented management of new challenges, are essential elements of Apollo Heights Ltd's corporate culture, enabling positive corporate development and defining Apollo Heights Ltd as an innovative, efficient and reliable construction company.

Certain parts of this corporate culture are further developed and made mandatory in the form of a Code of Ethics in the form of fundamental legal, ethical and moral conduct principles. Conduct in accordance with tax laws and the definition of taxes as a social obligation are part of the principles set out in the Code.


2. Taxes as a result of business activities by region

The establishment of companies or permanent establishments follows only these operational considerations. All Apollo Heights Ltd subsidiaries engage in active, operational business activities using physical resources and are not for tax planning or tax avoidance purposes.

Apollo Heights Ltd conducts impeccable and fair conduct with respect to taxes and duties. In doing so, Apollo Heights Ltd avoids aggressive tax planning and artificial constructions. All business activities follow the principle of “Tax follows Business” - all transactions are guided by operational and non-tax planning considerations.


3. The tax as a social contribution

The essence of Apollo Heights Ltd’s strategy is to achieve corporate goals while at the same time contributing to the development of society for all stakeholders.

Apollo Heights Ltd pays income tax, withholding tax, consumption tax and customs duties along its value chain in all countries in which the Group operates. You also pay sales tax and contributions. On the other hand, Apollo Heights Ltd also benefits from tax incentives and subsidies provided by public authorities in the course of their business.

In doing so, the group of companies takes its social responsibility as a taxpayer seriously and, through its impeccable behavior, contributes to the social, economic and social functioning of states.

Apollo Heights Ltd is committed to specific sites and regional markets through group companies and tax payment.


4. Compliance with legal requirements and compliance with OECD principles

Apollo Heights Ltd strives to comply with local laws by taking advantage of possible legal frameworks for taxation. To this end, the tasks and resources of tax administration are structured in such a way as to comply as closely as possible with the current regulations of the countries in which the group operates.

Before concluding new contracts, it must be ensured that the contract to be concluded complies with the existing tax obligations. During the term of the contracts, the group of companies fulfills its documentation obligations in accordance with the relevant laws and regulations, submits all declarations to be submitted on time and pays taxes.

Given the vast majority of the group's activities in Austria and the characteristics of its foreign operations, intra-group transactions between companies operating in different countries are limited. The price of such transactions is based on the principle of the normal market price fixed by the OECD, which is described in the transfer pricing documentation. We comply with international transfer pricing reporting obligations. Apollo Heights Ltd strives to follow the recommendations of the OECD (BEPS Action Plan) on transnational issues.

The collection of information by the tax authorities of different countries requires a wide range of reporting obligations. Apollo Heights Ltd strives to comply with these reporting obligations without exception.


5. Relationship with tax authorities and governments

Apollo Heights Ltd cooperates openly with public institutions and local tax authorities. Based on mutual respect, a constructive relationship is established and there is an opportunity for goal-oriented dialogue.

The complexity of the tax legal framework, the size of the business and the amount of tax liabilities may run the risk that our legal position will not be accepted by the tax authorities due to differing interpretations.

In such cases, Apollo Heights Ltd protects the interests of the group by analyzing the subject matter and wording of the law and respecting the objective set by the legislature. If necessary, Apollo Heights Ltd will take legal action to enforce openly communicated positions.

For reasons of legal certainty, Apollo Heights Ltd seeks to promptly request an interpretation of the disputed facts from the tax authorities through an audit or a request for information. Apollo Heights Ltd processes requests from the tax authorities quickly and appropriately.


6. Tax risk management and tax control system

The tax framework for globalized businesses is constantly changing and often complex. The need for explanation and interpretation by the authorities and management carries risks.

Apollo Heights Ltd does not want to take risks in terms of taxes. The system and control of tax administration, as well as its tasks and resources, are structured in such a way that tax and tax laws and regulations must be complied with.

We regularly analyze and mitigate risks through appropriate measures. To this end, tax management is in constant contact with all business areas and, if necessary, with external consultants.

Tax-related functions in the country are performed by local responsible staff or external consultants. They ensure the application and transfer of knowledge (for example through inspections, guidelines or training). Cooperation with auditors and external tax experts plays an important role in this.