Purpose
The purpose of this Tax Strategy is to set out the high-level principles directing the tax affairs of Ludgate Limited and its controlled subsidiaries (‘the Group’) for the financial year ended 30 June 2024.
The Group regards the publication of this Tax Strategy as complying with the Group’s obligations under paragraph 16(2) of Schedule 19 of the Finance Act 2016 to publish the Group’s tax strategy for the year ended 30 June 2024.
Principles
The Group manages its tax affairs to provide responsible and sustainable support to our business strategy. Based on an understanding of the needs of our stakeholders and corporate governance best practice, the Board has established the following fundamental principles for the management of taxes within the Group:
- Governance and Accountability – The Board understands its duties in terms of tax and its wider corporate responsibilities and puts strong emphasis on meeting the principles set out in this Strategy.
- Compliance – We comply with the tax law and practice in all of the territories in which we operate and disclose all relevant facts and circumstances to the tax authorities.
- Planning – Where we are required to make decisions on how we structure our commercial activities we will consider, among other commercial factors, the tax laws of the countries within which we operate with a view to maximising value on a sustainable basis for our shareholders.
- Tax risk management – Given the scale and international nature of our business, tax risks are an inherent part of our day-to-day operations. In line with the Group’s risk management approach, we proactively seek to identify, evaluate, manage and monitor tax risks to ensure they remain in line with the Group’s risk appetite.
- Tax authority relationships & regulatory development – We engage with tax authorities, including HMRC, with honesty, integrity, respect and fairness and in a spirt of co-operative compliance.
- The Group does not tolerate tax evasion or the facilitation thereof by members of its workforce or persons associated with the organisation.
Approach To Risk Management And Governance In Relation To UK Taxation
The Group includes a dedicated tax team made up of professionally qualified and experienced employees and has the support of the broader AUB Group Finance and Taxation teams.
The day-to-day implementation of the Tax Strategy is managed by the Group Head of Tax, supported by the Divisional Chief Financial Officer reporting to the Board.
Key tax issues are brought to the attention of the Audit Committee and Board, each body takes a keen interest in the effect of our approach to tax on the governance interests of all stakeholders in the business.
The Group Head of Tax is responsible for ensuring there is a framework for implementation of the Tax Strategy and the identification and management of tax risks on both transactions and ongoing business activities.
Attitude Towards Tax Planning As Far As It Affects UK Taxation
Where we are required to make decisions on how we structure our commercial activities we will consider, among other commercial factors, the tax laws of the countries within which we operate with a view to maximising value on a sustainable basis for our shareholders. Any tax planning undertaken will have commercial and economic substance and will have regard to the technical analysis, financial impact, any potential reputational impact on our business and internal resource commitment.
In cases of uncertainty around tax planning for a commercial transaction, the group will seek the guidance of professional advisers.
Level Of Risk That The Group Is Prepared To Accept In Relation To UK Taxation
The Group’s appetite for tax risk is low. All tax risks arising from business activities are assessed for negative impacts from both a financial and reputational perspective as part of the group’s risk and compliance framework. Significant tax risks are considered by the Board before strategic business decisions are taken.
Approach Of The Group Towards Its Dealings With HMRC
The Group engages with tax authorities, including HMRC, with honesty, integrity, respect and fairness and in a spirt of co-operative compliance. We will seek to resolve any disputed matters through pro-active and transparent discussions. Where it is necessary to clarify the appropriate interpretation of relevant tax law, and where it supports the Group’s Tax Strategy, we will take appropriate action in line with the relevant local requirements to resolve any matter in order to reach agreement.