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This page is produced in accordance with the requirement under Section 161 and Schedule 19 Finance Act 2016 for the company to publish its UK tax strategy on the internet and sets out the group’s approach to tax.
The tax strategy is owned by the company’s board with responsibility for operation delegated to the Chief Financial Officer. Accordingly the board is responsible for determining the group’s tax objectives and guiding principles which are set out below:
- To comply with all applicable tax laws and regulations.
- Seek to utilise available tax reliefs and incentives where available in a manner which is consistent with the government’s policy objectives.
- To ensure the group suffers no adverse reputational risk by not engaging in aggressive tax planning.
- To adopt the principles of collaborative compliance in its engagement with HMRC.
Approach of the group to risk management and governance arrangements in relation to UK taxation
The company’s approach to governance is to ensure that the company tax objectives and principles are met by having an efficient and effective tax control environment consistent with the organisations size and complexity. The components of the company’s tax control environment comprise: risk identification and assessment; tax processes and controls; communication and monitoring activity.
GRI’s approach to governance and risk management involves:
Tax risk identification – the company, in conjunction with its advisors conducts a process of risk identification based on a top down/bottom up approach. Having identified tax risk the company ensures it has appropriate processes and controls in place to manage that risk in in order to meet its tax compliance requirements. The group has developed a tax risk identification and control framework for this purpose.
Communication – Those responsible for tax matters regularly liaise with business units to monitor activity and discuss issues which could have an impact from a tax perspective which feeds into the risk identification process. Similarly, the finance function and its advisors raise awareness of tax matters that could impact the group’s risk profile.
Processes and controls – through a combination of appropriately qualified personnel (supplemented by external advisers where necessary), policies, procedures and systems, the tax risk associated with the group’s transactions and activity is managed and controlled, in order to meet the company’s primary tax objective of compliance with all tax laws.
Monitoring activity – ongoing checks are made of processes and procedures to ensure staff responsible for processing tax related matters perform their functions correctly. This includes input from external advisers who review the work undertaken by internal staff and where additional support and expertise is required to supplement internal resource in preparing tax returns.
Attitude of the group towards tax planning (so as affecting UK taxation)
The group’s approach to tax planning is to only undertake tax planning that is aligned with economic activity and is in accordance with the intention of the legislation. As such, the group does not undertake tax planning that could be regarded as tax avoidance.
The group will therefore seek to make use of intended government tax incentives and exemptions. Relief for Research and Development activity is the most significant of such incentives being designed to promote investment in leading edge scientific innovation.
The level of risk in relation to UK taxation that the group is prepared to accept
The group adopts an approach to risk acceptance that is consistent with its objective of aiming to comply with all tax laws. The group is subject to the Senior Accounting Officer requirement to ensure it has taken reasonable steps to establish and maintain tax accounting arrangements that enable the tax liabilities of companies within the group to be calculated accurately in all material respects. The group follows HMRC guidance in this respect to ensure its obligation is met.
Tax legislation is often complex and subject to interpretation. Consequently, if uncertainty arises in relation to a significant and complex tax position the group seeks to minimize the level of risk caused by the uncertainty as to the interpretation by seeking expert and independent advice or through discussion with HMRC.
In relation to uncertainty in relation to tax matters the group will only adopt a filing position where, notwithstanding the uncertainty, the group believes the filing position it has taken would prevail if the matter were to be litigated in the courts.
The group’s approach towards its dealings with HMRC
The group seeks to adopt an open, cooperative and professional working with HMRC. Should disagreements over tax arise, the group endeavours to work proactively with HMRC to seek to resolve all issues by agreement where possible.
Dated: 28th December 2018 for the 2019 year ahead