This document is published in accordance with paragraph 16(2) of Schedule 19, Finance Act 2016 in respect of the year ended 30 September 2026.
The Victrex Group (‘Group’) is an innovative world leader in high-performance polymer solutions, offering transformational and sustainable solutions that address world material challenges. Our headquarters and primary manufacturing facilities are based in the UK and we are a major exporter, with over 98% of Group sales generated from outside of the UK. The Group employs over 1,100 people worldwide (over 800 in the UK) and our annual sales for the year ended 30 September 2025 were £293 million.
The Group’s strategy is to be the world leader in high-performance PEEK and PAEK polymer solutions. We seek to differentiate Victrex from our competitors by focussing on existing and new applications in the PEEK and PAEK polymer space, developing new polymer grades and product forms, including composites, and building new markets in ‘parts’ alongside our core polymer offering. Our tax strategy is aligned with this business strategy to enable the Group to continue to move quickly on a secure basis of tax compliance.
Our approach
The Group is committed to manage our tax affairs in a responsible and transparent manner, complying with statutory obligations and disclosure requirements, and having due regard for our wider reputation and corporate social responsibilities.
Through our business activities the Group pays a substantial amount of tax, encompassing corporate income tax, employment taxes, environmental taxes (e.g., the climate change levy), and other taxes such as business rates, stamp taxes, import duties. The Group also collects and pays employee taxes and sales taxes.
A significant proportion of the Group’s activities (operations, employees, and assets) are based in the UK. Accordingly, the Group pays a substantial amount of our overall tax liability to the UK authorities.
The Group has clear and consistent tax policies and procedures to support our tax strategy, which are subject to the same level of robust internal controls, risk management, assurance processes, and external audit as the rest of our business. The Group’s Code of Conduct sets out what is expected of Victrex and our associates, and our approach to tax aligns with this Code.
Governance and risk management
The Group understands the importance of maintaining effective tax standards across the Group, given that tax has significant cash and accounting impacts.
Proactive and timely communication of business changes and transactions is essential to allow effective tax management. Effective communication beginning at the planning stage ensures that tax risks and opportunities inherent in projects and transactions are managed effectively.
The Board is ultimately responsible for tax governance, ensuring there is an appropriate framework in place to oversee the management of tax risk. The Board has delegated this responsibility to the Chief Financial Officer who reports to the Board as required.
The Group Tax Manager is responsible for day to day management of the Group’s tax affairs. This individual holds relevant professional qualifications and is required to maintain their professional competence via the CPD requirements of these professional bodies.
The competence of the Group finance team is ensured via annual tax training in accordance with their roles. All staff involved in tax processes, are trained in the tax related aspects of their role. In our regional finance teams, external advisers are commonly used to support local tax compliance.
External advisers may also be used in the UK and regionally to assist with tax projects, e.g., transfer pricing, capital allowances, R&D Expenditure Credits (“RDECs”), operational changes, exceptional items, and large and complex transactions.
Acceptable levels of tax risk
The Group’s approach to tax risk is a carefully calibrated part of our business model aligned to our strategic and corporate objectives, as set out in the Annual Report.
The Group is not prescriptive in terms of levels of acceptable tax risk. However, our primary objective is to comply with legal requirements in the taxing jurisdictions in which the Group operates. We therefore consider that we have a prudent approach to tax risk. Significant matters in which there is doubt in relation to tax risk are escalated to the Chief Financial Officer and/or the Board for consideration.
As part of our internal control processes, the Group seeks to reduce the level of tax risk arising from our operations as far as reasonably practicable. Tax risks are recorded in a tax risk register which forms part of the finance risk register, which in turn feeds into the Group risk register.
Tax planning
The Group only engages in tax planning that supports the business’s commercial and economic activities and does not engage in artificial tax arrangements or in planning that may have a negative impact on the business and our stakeholders. The level of risk which the Group accepts is consistent with our primary objective of ensuring compliance with legal requirements in our tax affairs.
Pursuant to the Group’s strategy of product leadership, we invest heavily in research and development (approximately 5-6% of Group revenue). The Group seeks to maximise relevant tax incentives provided by the territories in which we operate, e.g., incentives related to research and development, patent-related income, and capital allowances.
As a global business, the Group follows relevant Tax Treaties, OECD guidelines, and local law relevant to our international activities, such as transfer pricing and permanent establishment rules. The Group applies arms-length pricing to intra-group transactions (i.e., the price that would be charged by an unrelated party for carrying out the same transaction), based on external pricing benchmarks with a full review every 3 years (or more frequently if required by changing circumstances). We aim to formally register a local presence (e.g., a permanent establishment) in all territories where this is required by our activities and local law.
Furthermore, the Group is compliant with our obligations under the UK’s Corporate Criminal Offences of failure to prevent the facilitation of tax evasion and failure to prevent fraud.
Relationships with Tax authorities
The Group maintains open, transparent, and constructive relationships with HMRC and other tax authorities in territories where the Group has a presence, and will seek to work with them collaboratively in relation to our tax affairs, including any tax audits, where practicable.
The Group discloses any relevant planning we undertake to applicable tax authorities in line with the legal disclosure requirements and criteria set out by local territories.
When submitting tax returns and other communications to HMRC and other tax authorities, the Group discloses relevant facts and identifies any transactions or issues where we consider there is potential for the tax treatment to be uncertain. Any errors in submissions that are identified retrospectively are disclosed to the relevant tax authorities in a timely manner.
Approval
This strategy was formally approved at the Victrex PLC Board meeting on 17 September 2026 and will be reviewed annually.