The Square Enix Group (the ‘Group’, consisting of Square Enix Holdings Co., Ltd., a company incorporated in Japan and its subsidiaries) boasts a valuable portfolio of intellectual property including: FINAL FANTASY®, DRAGON QUEST®, , and SPACE INVADERS®.

Square Enix Limited is a London-based, wholly owned subsidiary of Square Enix Holdings Co., Ltd. Square Enix Limited (and subsidiaries) develop, publish, distribute and license SQUARE ENIX®, EIDOS® and TAITO® branded entertainment content in Europe and other PAL territories.

The Square Enix Group has the following UK companies, all of which are covered by this UK Tax strategy disclosure:

• Square Enix Limited
• Square Enix (2009) Limited
• Eidos Ltd.
• Sci Games Limited

This document has been approved by the Group Chief Accounting Officer (CAO), and satisfies the disclosure requirements under Schedule 19 (2) of the UK Finance Act 2016. This tax strategy was published on 31 March 2023, and will be relevant for the financial year ending 31 March 2024.

Group Tax Strategy

The Group Tax strategy is approved by the Group CAO, and sets out the core principles that govern the tax policy for all Square Enix Group companies, including:

• An important aspect of strong corporate social responsibility is tax transparency and a commitment to tax compliance;
• Square Enix strives to pay the correct amount of tax, in the jurisdictions in which it is due at the right time in accordance with the tax laws and regulations of the countries in which it does business;
• Paying the right taxes in these countries contributes to their economic and social development, which also benefits the Group.
• The UK companies in the Square Enix Group all follow these principles in managing their tax affairs.

Tax Governance

Tax forms part of the accounting and finance function of the business. The Group CAO has overall responsibility for Group tax matters. Local Financial Directors (or equivalent) are responsible for tax in their local jurisdictions.

The business effectively manages tax risks through the timely gathering and sharing of information across the Group and regular communication between Group companies. There is regular communication between the Group CAO and the Western Finance Directors in order to review worldwide tax issues.

In the UK, day-to-day tax operations are delegated to the UK Group Head of Finance.

The UK Group Head of Finance communicates regularly with staff from across the UK and Western business to keep informed of any changes, and monitors developments in tax legislation to understand its impact on the UK Group. The UK Group Head of Finance is in regular contact with the Western Sr. Corporate Controller, as well as relevant members of the Group’s Corporate Headquarters.

UK tax risks are managed in line with the overall Group Tax strategy and follow business procedures and internal controls required to comply with J-SOX reporting rules. The UK Group Head of Finance reviews UK specific risks and maintains a UK tax risk register.

Approach to tax risks and tax planning

The Square Enix Group maintains a low tax-risk profile whilst maximizing long-term corporate value and fulfilling all tax responsibilities. The Group commits to not entering into tax avoidance arrangements or artificial planning that does not follow commercial reality or is at odds with the purpose of local legislation. Square Enix does not use tax havens for tax avoidance purposes.

The approach to tax in the UK is in line with the Group strategy, and where a tax treatment is uncertain, the impact on the Group is evaluated and resolved with an aim of maintaining low risk. The Group operates within a system of complex international tax rules, and therefore where there are matters of uncertainty; Square Enix will engage external professional advisors for support to ensure it remains fully compliant in the UK and overseas.

Where available and aligned with business activities, Square Enix will take advantage of available UK corporate tax reliefs for its activities, including those available for research and development and those specifically aimed at video games companies. In the UK, Square Enix also contributes through payment and collection of a variety of other taxes including VAT, employment taxes (including national insurance), import duties and withholding taxes.

Relationship with HMRC

The Group seeks to foster a transparent, professional and cooperative approach to its relationship with HMRC. Where possible the Group will look to work in real-time with HMRC, seeking to clarify matters of uncertainty in advance, including engaging in Advance Pricing Agreements to confirm related party transactions with overseas affiliated companies.