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The Group's tax strategy reflects its status as a business which requires strong governance and consideration of our reputation. Our tax strategy also reflects the nature of our business, which requires strict compliance with tax laws for our clients as well as ourselves.
In pursuit of this the Group is committed to:
The board of directors delegate the day to day management of tax affairs to the Finance Director (who is also Senior Accounting Officer), Head of Operations and the Operations and Service Director. These individuals have clearly defined roles and responsibilities which are set out in the Group’s internal finance manual. All directors and employees who undertake any part of the tax calculation and payment processes must adhere to this document and are required to sign it to confirm their understanding after any update has been made, which is a minimum of once per year.
Only those named in this document are authorised to make decisions and sign filings and other documents in relation to the Group's tax affairs. There is a process to ensure that decisions are taken at appropriate levels across the Group and at a Company level. Any changes to individuals and their responsibilities would require Board approval. The Board has overall governance of the Groups tax affairs.
The Group takes a prudent attitude towards tax planning and ensures compliance with relevant laws before considering tax efficiency. The Group will not engage in artificial transactions the sole purpose of which is to reduce tax and will not engage in tax efficiencies if the arrangements impact upon the Group's reputation, brand, corporate and social responsibilities, or future working relationships with HM Revenue & Customs (HMRC).
Where there is a material doubt as to the tax treatment of any particular transaction or where the tax guidance is unclear or the Group does not feel it has the necessary expert knowledge to assess the tax consequences adequately, external advice will be sought to support the Group's decision making process and/or the Group will seek to resolve the uncertainty by dialogue with the tax authorities.
The Group's aim is keep its UK tax risk low by:
The Group complies with all relevant legal disclosure and approval requirements and all information is clearly presented to HMRC as appropriate. In its dealings with HMRC, the Group acts in an open, honest and transparent manner to avoid unnecessary disputes with HMRC. The Group intention is to comply with all relevant legal disclosure and approval requirements and clearly present all information to HMRC as appropriate.
In making this strategy available the Group is complying with its duty under paragraph 16(2) of Schedule 19 of Finance Act 2016.
Original Issue Date: March 2018
Reviewed and updated: February 2020