Our aim is "to manage the tax affairs of the Group as efficiently as possible to support the commercial objectives of the Group. We manage our tax affairs in accordance with the letter and spirit of the law, whilst seeking to minimise the tax paid by the Group. We seek to maintain strong compliance controls and operate a policy of open and transparent dialogue with the relevant tax authorities."
We strive to achieve our aim for tax by delivery of our four key tax objectives outlined below which are aligned to our overall business strategy objectives.
- The tax team are a critical business partner, delivering clear, timely and relevant technical advice to enable us to achieve our business objectives and manage our tax affairs as efficiently as possible.Business teams within our group understand the importance of engaging the tax team prior to any significant decisions or transactions. The in-house tax team have appropriate qualifications and experience to assist and must ensure technical knowledge is maintained, communicating relevant changes in tax legislation on a timely basis. External advice is sought where required and the Group Tax Manager and Chief Financial Officer meet regularly to discuss key tax matters which are also raised with the Board where deemed of significant importance or magnitude. We have a zero-tolerance policy to tax evasion and the facilitation of tax evasion. In line with the Corporate Criminal Offence of Failure to Prevent the Facilitation of Tax Evasion introduced in the Criminal Finances Act 2017 we seek to apply reasonable prevention procedures to prevent any associated persons of the business from facilitating tax evasion.
- We will maintain a suitable risk rating from HMRC, that reflects our accepted level of tax risk, through strong governance procedures and increasing use of technology. Through our Tax Governance Policy, we strive to ensure that all key tax processes and controls are in place to comply with the Senior Accounting Officer and other reporting and compliance requirements. Tax is managed at a senior level via regular dialogue between the Chief Financial Officer and Group Tax Manager with a summary of key tax matters presented annually to the Board. An annual rolling testing program is in place to review key tax processes; where issues are identified, these are promptly investigated and remedial action is taken where necessary. As part of this program, opportunities to innovate using technology are explored where they deliver cost savings or improve process efficiency and quality.
- We will consider tax planning opportunities that minimise our tax costs, but only where they are commercially driven and are aligned to our tax risk appetite. Where a number of options exist to achieve the same commercial outcome, we will consider the most tax efficient. Appropriate external tax advice is sought prior to any significant business transaction and a second opinion will be sought for large or unusual matters. All tax planning discussions must consider the downside risk to the Group, balanced against the upside benefit, and ensure alignment with our overall risk appetite. All tax planning requires sign-off by the Chief Financial Officer.
- We maintain an open and transparent dialogue with HMRC through our Customer Compliance Manager and other key individuals. The Group continues to engage with HMRC in respect of enquiries and ongoing matters, in an open and transparent manner and more formally via our annual risk review meeting. We aim to maintain a risk rating from HMRC that is deemed appropriate by the Chief Financial Officer and the Board having considered all the relevant factors at any given time. We will often seek the view of HMRC on uncertain tax positions.
By making this strategy available for the financial year ending 25 September 2021 we are complying with our duty under Schedule 19, paragraph 16(2) of Finance Act 2016.