This strategy was approved by the Board on 24 October 2019. This UK tax strategy covers all of the Gamma UK companies and its publication follows the requirements set out in UK Finance Act 2016 Schedule 19.
Gamma’s approach to management of its tax affairs is driven by the following three objectives:
The above objectives mean that Gamma has a tax strategy and policies that balance the need to build and maintain trust with stakeholders (including the UK Government) while also maximizing the return for investors.
Given the size of the business, the tax risk profile of Gamma is considered relatively low for the principal reasons listed below:
The principal tax risks are reviewed on an ongoing basis by the Chief Financial Officer (who is also the Senior Accounting Officer for reporting purposes).
Gamma’s approach to tax risk is aligned to its wider corporate governance and internal risk management processes. Gamma, as a listed group, has broader systems and controls in place (for example it maintains a risk register). Significant risks of all types are escalated to the board. Gamma’s business activities are regularly reviewed to make sure they are compliant with UK tax law as part of Gamma’s Senior Accounting Officer obligations.
Tax planning and compliance is part of the Finance function of Gamma and the Chief Financial Officer (who is a Board member) is ultimately responsible for the Group’s tax strategy and policies.
Tax strategy and policy issues are assessed on a case by case basis by the Chief Financial Officer in accordance with this strategy.
Day-to-day tax matters are delegated to the finance team of in house professionals located in a single office, with appropriate review by the CFO. Each member of that team holds a recognised accounting qualification and engages in regular CPD.
As a UK listed company, the Group has a robust suite of financial systems and controls in place to ensure that all financial transactions are accurately reported and the tax thereon is calculated correctly.
Matters which require judgement are reserved for members of the finance team with a professional qualification and ultimately the CFO. External advice is sought from the major accounting firms and legal practices as required.
Where it is deemed appropriate, Gamma will also consult with HMRC directly on matters which are unclear or which contain significant levels of judgement.
This Tax strategy is reviewed annually by the Group’s Audit Committee and Board.
Ultimately responsibility for the Strategy rests with the CFO who is a Board member.
The Group is committed to acting with integrity and transparency. The financial professionals who deal with tax planning and compliance are expected to adopt this approach in all tax matters. They are also expected to maintain the high ethical standards demanded by the professional bodies to which they belong.
Our tax strategy and policies require that we fully comply with UK tax law. We aim to make timely and accurate tax returns and payments that reflect our fiscal obligations to Government.
Where it is practical to do so, we aim for certainty on the tax positions that we adopt.
However, on occasion tax law can be unclear at times or subject to interpretation. Moreover, interpretation of that law may be opposed to Government’s interpretation.
Our policy is:
To support us in ensuring that we have interpreted tax law and its spirit correctly, we seek advice from large accounting firms, legal firms and/or tax counsel as appropriate.
For example, we do not use artificial tax avoidance schemes or use tax havens to reduce the Group’s tax liabilities.
Equally to ensure that we take advantage of all tax opportunities which are open to us we work with professional advisors to understand changes in legislation.
Minimising the Group’s tax liabilities by recognising appropriate legislative concessions and reliefs is of benefit to customers and shareholders.
The Group’s tax strategy and policies seek to make use of such appropriate reliefs and to control the Group’s tax costs.
Whilst seeking to minimise tax liabilities for the benefit of customers and shareholders, the Group’s policy is not to take an aggressive interpretation of tax legislation or use artificial tax avoidance schemes.
In summary, in accordance with CBI principles, we will only engage in tax planning when it is aligned to our commercial and economic activity and does not lead to an abusive result.
Gamma’s level of acceptable tax risk is considered at least annually by the CFO and Board. They will take the needs and interests of stakeholders into account when consider the level of risk but ultimately will ensure that Gamma acts with integrity and transparency and meets the criteria set out above.
Individuals are not given delegated responsibility which would allow them to set their own level of risk which could be taken in tax planning. The Gamma finance team is based in a single location and any member of the team who is involved in tax planning has been instructed not to adopt a tax position without consultation; every member of the team has full access to the CFO.
The CFO will keep the Board up to date on tax matters and will take specific matters to the Board for consideration on an exceptional basis particularly if there were doubts over how to apply the tax strategy to a specific set of circumstances.
An important part of our tax strategy is the maintenance and development of a strong, proactive working relationship with HM Revenue & Customs (“HMRC”).
We are transparent with HMRC and will seek guidance as to the intended tax consequences of either new business practices or new legislation. Where these require interpretation or are especially complex, we will work with HMRC on a real time basis to determine the amount of tax due.
We understand the value of our financial reporting to customers, investors and other stakeholders. We work to provide enhanced, transparent and balanced disclosure in communicating our tax affairs.