Bentley Systems, Incorporated and its Subsidiaries (Bentley), are publishing their tax strategy

Tax Strategy

Bentley is committed to (i) complying with laws in a responsible manner and (ii) building and maintaining professional and constructive working relationships with tax authorities based on principles of mutual transparency and trust.

These commitments, which are explained in more detail below, apply to all countries and all employees.

Tax Planning

Bentley manages tax costs by maximizing the tax efficiency of business transactions. This includes taking advantage of available tax incentives and exemptions. This must be done in a way which is aligned with the Bentley’s commercial objectives and meets its legal obligations and ethical standards. It must also be done in a way that gives a tax result Bentley reasonably believes is not contrary to the clear intentions of the legislation concerned.     

Relationships with Tax Authorities

Bentley is committed to building constructive working relationships with tax authorities, through openness and transparency, in order to remove uncertainty in the tax treatment of its business transactions. Where appropriate and possible, Bentley enters into consultation with tax authorities to help shape proposed legislation and future tax policy.

Approach to Dealing with Tax Risk

Bentley seeks to reduce the level of tax risk arising from its operations as far as is reasonably practicable by ensuring that reasonable care is applied in relation to all processes which could materially affect its compliance with its tax obligations.

Governance

Bentley, as a publicly traded company, has an internal control framework that upholds policies and procedures to support its tax positions. The Chief Financial Officer (“CFO”) is responsible for Bentley’s tax risks overall and the VP of Tax manages tax risk in the jurisdictions in which it operates. Together they provide guidance and advice to the Board of Directors in conjunction with Bentley’s advisors.

The Board has approved this approach. The Bentley Audit Committee oversees Bentley’s tax affairs and risks through periodic reviews. Bentley’s Governance Framework is used to manage tax risks, establish controls, and monitor their effectiveness. The VP of Tax is responsible for ensuring that appropriate policies, processes, and systems are in place and that the global tax team has the required skills and support to implement this approach.

Bentley regards the above as complying with its duty to publish its U.K. tax strategy under paragraph 16(2), Schedule 19, Finance Act 2016.

Board approval of updated policy adopted December 8, 2022
Date published December 16, 2022