MSCI Inc. Tax Strategy

MSCI Inc. (“MSCI” or “the Company”) is publishing this strategy statement in relation to its United Kingdom (“U.K.”) subsidiaries’ approach to tax risk management and attitude to tax planning in the U.K. This statement is for the financial year ending 31 December 2022 and is made in compliance with the requirements outlined in Part 2 of Schedule 19 of the Finance Act 2016. The strategy below applies to taxes in the U.K.

MSCI’s overall tax strategy is to:

• Comply with legislative requirements in relation to tax
• Submit tax returns and make tax payments by the due dates
• Pay the correct amount of tax based on the profits earned by the business
• Continue to maintain an open, honest and proactive relationship with HMRC
• Have in place risk management and control procedures in relation to tax
   

MSCI’s approach to Tax Risk Management and Governance arrangements

The responsibility for MSCI’s tax strategy, risk and the supporting governance framework is the responsibility of the Chief Financial Officer (“CFO”). Day to day responsibility for these functions sits with the Chief Tax Officer (“CTO”) who reports to the CFO. The MSCI Tax department consists of qualified and experienced finance professionals and works with the Global Controller’s organization, which is similarly staffed, to manage MSCI’s tax affairs globally. A full time, UK based role with sufficient UK tax qualifications and experience is part of the Tax department, reporting directly to the CTO and assists in managing the UK tax affairs of the group.

MSCI has robust internal procedures and compliance programs to ensure MSCI meets its tax compliance responsibilities. Those procedures are reviewed and tested by MSCI’s Internal Audit department and the Tax department regularly reports to MSCI’s Enterprise Risk function to assess developing risk areas.

Ultimate oversight of MSCI’s tax policies and risk lies with the Audit Committee of the independent board of directors. The CTO regularly updates the Audit Committee on all significant tax matters and developments.

MSCI requires every employee to certify annually their commitment to the Company’s Code of Conduct which stresses MSCI’s commitment to ethical, transparent and responsible behaviour in everything MSCI does. MSCI’s approach to tax is aligned with the Code of Conduct.
 

MSCI’s attitude to Tax Planning

MSCI recognizes that it has a responsibility to pay an appropriate amount of tax in the U.K. Against this MSCI must balance its responsibilities to maximize MSCI’s sustainable returns to shareholders. MSCI will not undertake any tax planning that cannot be sustained by the commercial requirements of the group and does not have economic substance. MSCI will not undertake any tax planning unless MSCI believes that the strategy is compliant with tax legislation and more likely than not to succeed.
 

MSCI’s attitude towards Tax Risk

MSCI sees compliance with tax legislation as key to managing MSCI’s tax risk. MSCI’s attitude towards risk is to be compliant in the U.K. Where there is significant uncertainty or complexity relating to an identified risk, external professional tax advice may be sought. MSCI uses reputable tax advisers to assist in the fulfilment of its tax compliance responsibilities where it does not have appropriate local resources internally.
 

MSCI’s approach to dealing with HMRC

MSCI engages with HMRC in a transparent manner, with the highest degree of integrity, in order to foster cooperation and trust. MSCI seeks to handle any queries or disputes through pro-active discussion with HMRC.

Updated statement was published in December 2022