Global Tax Policy

Preface:

We are a global leader in flavor that stands with our stakeholders – our employees, our communities, our consumers, our shareholders and our customers.   As part of our principle of Purpose-led Performance, we are committed to delivering top-tier financial results while also helping to improve the health and well-being of people, build vibrant communities and make a positive impact on our planet.

This statement establishes a global tax policy for McCormick & Company, Inc., its subsidiaries and affiliates (collectively "McCormick", "we" or "our") that is consistent our Purpose-led Performance principle. The policy has been approved by the McCormick Board of Directors.  

Approach to Tax Planning & Compliance

We are committed to comply with the spirit as well as the letter of all applicable tax laws and regulations, including the arm's length standard in transfer pricing from the Organization for Economic Cooperation & Development ("OECD") guidelines. We pay the correct amount of tax in the countries, states, and other jurisdictions where we operate or conduct business.  Our tax structure aligns with our business operations and growth strategy.  We do not transfer value created to low tax jurisdictions, do not use tax structures for tax avoidance and do not use secrecy jurisdictions or so-called "tax havens" as defined in the OECD standards for jurisdictional transparency. In the rare situations where an entity in a "tax haven" is acquired as part of a larger transaction, we will assess whether the entity meets the requirements of the Global Tax policy and will take appropriate actions where necessary. In addition, we do not engage in tax planning that is contrary to legislative purpose and intent. Where more than two legal options are available and fully align with the commercial economics of the transaction, the most tax efficient method may be pursued, including obtaining credits, exemptions and relief where appropriate.   

Relationship with Tax Authorities 

McCormick interacts with tax authorities with integrity and in a transparent, honest manner in all aspects of compliance and tax audit defense.  In addition, we proactively engage and discuss, where possible, any significant transactions in a courteous and timely manner.

Tax Risk Management Compliance, Controls and Governance

McCormick adopts a balanced approach to tax risk management consistent with our Purpose-led Performance principle.  Our global operations may entail tax risks including legislative and regulatory changes, uncertainty in interpretation of applicable law, operational and compliance risks, and the impact of these risks on our reputation. We provide an appropriate level of resource and training for employees to ensure compliance with applicable laws.  We review uncertain tax positions on a periodic basis and monitor and analyze changes in applicable tax law. In addition, we seek external tax advice from accounting firms and/or law firms when there is a need for guidance and support with respect to complex issues or transactions. We minimize these risks through internal controls. We have review and approval procedures by appropriate members of global tax team leadership and our senior management and oversight by the Audit Committee of our Board of Directors.


For UK purposes: This policy is published by McCormick Europe on its own behalf and as the head of a subgroup of companies.  This policy applies to all the UK companies within the subgroup pursuant in respect of the 2021 financial year in compliance with their duties under paragraphs 19(2) and 22(2) (as applicable) of Schedule 19 UK Finance Act 2016.