Introduction

JUUL Labs UK Limited (“JL UK”) was incorporated in 2017, and is a subsidiary of JUUL Labs, Inc. (“JUUL Labs, Inc.”), a company registered in the United States of America, and headquartered in Washington, D.C.

Our mission is to transition the world’s billion adult smokers away from combustible cigarettes, eliminate their use, and combat underage usage of our products.

JUUL Labs, Inc. conducts business in an ethical manner, guided by the enduring principles of our founders and an unwavering commitment to integrity. Our business has a strong focus on corporate responsibility, and we see responsible administration and payment of taxation as a responsibility of our business.

JUUL Labs, Inc.’s consolidated group includes JL UK as at October 7th, 2022.

The Role of Tax within JUUL Labs, Inc.

JUUL UK is subject to various UK taxes, including but not limited to: corporate taxes, customs duties, stamp duties and employment taxes.

(a) the approach of the group to risk management and governance arrangements in relation to UK taxation:
JUUL Labs, Inc. is committed to conducting business in accordance with all applicable UK tax laws. JUUL Labs, Inc. does business in multiple tax jurisdictions throughout the world and is subject to various complex and changing tax legislation, which are subject to interpretation. Any potential tax exposure is managed by JUUL Labs, Inc.’s tax function based in the US, which seeks advice from outside tax consultants and/or legal counsel on uncertain tax legislation when necessary.

(b) the attitude of the group towards tax planning (so far as affecting UK taxation):
JUUL Labs, Inc. conducts all transactions on an arm’s length basis in accordance with current OECD principles. JUUL Labs, Inc.’s tax policy is to err on the side of conservatism around tax planning and business decisions that are made within JUUL Labs, Inc. are not driven by avoidance of taxes.

(c) the level of risk in relation to UK taxation that the group is prepared to accept:
JUUL Labs, Inc. is committed to minimizing tax risk and exposure with HMRC. Uncertain tax positions are analysed and reviewed regularly by JUUL Labs, Inc.’s management and processes and controls are in place to identify and mitigate key risks.

(d) the approach of the group towards its dealings with HMRC:
JUUL Labs, Inc. incorporated two new UK legal entities in the tax year ending December 31, 2019 and is committed to building sustainable and respectful relationships with HMRC.

Further Information

JUUL Labs, Inc.’s approach to tax is reviewed and regularly updated. This tax strategy was approved for publication by JUUL Labs, Inc. on August 24, 2020.