This document has been approved by the board of the Company and sets out its policy and approach to conducting its tax affairs and dealing with tax risk.
This strategy applies from the date of publication until it is superseded.
The Company’s policy is to comply with all relevant laws, rules, regulations, reporting and disclosure requirements and to timely pay the correct amount of tax to all taxing authorities with which the Company has a tax obligation.
The governance is supervised by the rigid internal control procedures and reports to the board of directors.
The Company has established a regular and ongoing review of its tax risks with strong internal controls in place to substantiate and mitigate its tax risks to materially acceptable levels. As part of this process, the Company has formal Quarterly certification procedure including the identification, evaluation, monitoring and reporting of tax issues and risks.
Detailed documentation of these reviews is maintained, which, if necessary, allows them to be raised up through the appropriate levels of management and/or the HMRC as required.
The Company will not engage in tax planning other than that which is permitted by law and which supports genuine commercial aims. Where commercial activities and transactions may be structured in ways which have different outcomes for tax purposes the Company may structure those actions in a way which legitimately provides the most advantageous outcome. In the event that there is any doubt as to whether the structure of the commercial actions and the tax results might be contrary to the intentions of Parliament or perceived to conflict with the spirit of the law then the Company will evaluate the actions through its internal tax governance arrangements and, where appropriate, discuss the matter with HMRC.
The Company’s aim is to minimise the level of risk in relation to UK taxation at all times. The Company is not prepared to accept a level of risk that exposes it to reputational harm or which could adversely impact its relationship with HMRC.
To ensure that the level of risk is kept as low as possible, a number of risk management policies and governance arrangements are in place, including tax reviews and tax implications of new processes or business methods.
The Company’s approach to dealing with HMRC is to maintain an open, professional and transparent relationship in relation to tax planning, compliance, strategy, risks and significant transactions. The Company commits to make full and accurate disclosures in tax returns and in correspondence with HMRC. The Company shall co-operate with HMRC at all times and deal with issues in a timely and collaborative manner.
The Company shall comply with its legal obligations and interpret legislation in a reasonable way that is aligned with the intentions of Parliament. Where genuine differences of opinion occur on the application of tax law, the Company will first seek to resolve these with HMRC through open dialogue and with reference to the relevant legislation and case law.