BRITISH BUSINESS BANK BRITISH BUSINESS BANK TAX POLICY

Similar documents
Mothercare plc Group Tax Strategy

UK Tax Strategy. Subsea 7 International Holdings (UK) Ltd. December 2017

Genesis Housing Association Tax Strategy. Year Ended 31 March 2017

Tax Strategy Brunel International N.V.

BEPS Action 12: Mandatory disclosure rules Response by the Chartered Institute of Taxation

Group Taxation Strategy. Year ended 31 December 2018 issued on 11 December 2018

A General Anti-Abuse Rule. Consultation document Publication date: 12 June 2012 Closing date for comments: 14 September 2012

Hoyer UK Group Tax Strategy

Government response to House of Lords Select Committee on Economic Affairs 1 st report of Session :

2017 UK TAX STRATEGY. Formica UK Group

Flint Group Annual Tax Strategy year ended 31 December 2017

STEP response to HMRC s consultation on Tax Avoidance Involving Profit Fragmentation.

Criminal Facilitation of Tax Evasion

ICBC LONDON Tax Strategy

SUPPLEMENTARY PROSPECTUS FOR POTENTIAL INVESTORS IN THE UNITED KINGDOM DATED 26 NOVEMBER 2018

Professional conduct in relation to taxation

Prudential Group. Sanctions Policy. September 2014

Partnerships: A review of two aspects of the tax rules 2) Profit & Loss Allocation Schemes Response by the Chartered Institute of Taxation

Offshore employment intermediaries

MICRO FOCUS INTERNATIONAL PLC and its subsidiaries TAX STRATEGY

Where the GAAR is in point, the tax advantages are adjusted on a just and reasonable basis.

MAIN SECURITIES MARKET ADMISSION TO TRADING RULES

GLOBAL ANTI-CORRUPTION POLICY

LRS Anti-Tax Evasion Policy

To Wind-Up Or To Sell, That Is The Question?

Reporting of relevant matters of interest to UK charity regulators. A guide for auditors and independent examiners

ITV plc Policy on the Independence of External Auditors (Including the provision of non audit services)

SoftBank UK Tax Strategy

HMRC Governance Protocol on compliance with the Code of Practice on Taxation for Banks

ANTI-FACILITATION OF TAX EVASION POLICY

Recent BEPS related legislation/guidance impacting Luxembourg

Our taxes explained. A guide to our tax strategy and tax profile June 2017

Tax Enquiries: Closure Rules Response from the Low Incomes Tax Reform Group (LITRG)

NZQF Offshore Programme Delivery Rules 2012

Anti-bribery policy. Lynas Corporation Limited ACN

Draft Partnership Agreement relating to [Name of ECF] Amending and restating a partnership agreement dated [Date]

Tax Strategy November 2017

Code of governance for resolving tax disputes

Tax Strategy. March 2018

Our tax policy is to pay the right amount of tax at the right time in each of the countries in which we operate. Tom Stoddard Aviva Group CFO

Association of Accounting Technicians response to Intermediaries Legislation (IR35) Discussion Document

Pennon Group Contributing to society through a responsible approach to tax. March 2018

European Investment Bank. EIB Policy towards weakly regulated, non-transparent and uncooperative jurisdictions

Deferring the payment of corporate exit charges Response of the Law Society of England and Wales February 2013

The Advantages of the UK as a Location for a Holding Company. David Gibbs May 2015

Breaching anti-bribery and anti-corruption law is a serious offence and represents a failure of our commitment to business integrity.

Group Tax Strategy January 2018

14531/1/14 REV 1 AS/JB/df 1 DG G 2B

GrainCorp UK Tax Strategy

IRIS Group of Companies Customer Data Processing Terms

CARIBBEAN DEVELOPMENT BANK STRATEGIC FRAMEWORK FOR INTEGRITY, COMPLIANCE AND ACCOUNTABILITY PILLARS I AND II INTEGRITY AND ETHICS POLICY

TAX STRATEGY AND APPROACH TO TAX

Decree No. 67/2018 Coll.

Standards of Business Conduct Policy

VC CATALYST. Request for Proposals

Anti-facilitation of Tax Evasion Policy

Association of Accounting Technicians response to HMRC s technical consultation Tackling disguised remuneration

CONFLICTS OF INTEREST & ANTI- BRIBERY POLICY

Tackling offshore tax evasion A requirement to notify HMRC of offshore structures: CIOT Comments 27 February 2017

CONTRACT FOR SERVICES THIS AGREEMENT is made on this day 20 BETWEEN:

Vodafone Hutchison Australia Pty Limited Board of Taxation Tax Transparency Code Report for the financial year ended 31 December 2016

Anti-Bribery & Corruption Policy

Association of Accounting Technicians response to HM Revenue and Customs consultation Tackling tax evasion: legislation and guidance for a corporate

Continuing Professional Development (CPD)

COMMISSION REGULATION (EU)

MODERN WORKING PRACTICES: EMPLOYMENT STATUS RULES FOR EMPLOYMENT RIGHTS AND TAX/NIC

TAXREP 56/14 (ICAEW REPRESENTATION 136/14)

Penspen Group Legal Code of Conduct Anti-Bribery&Corruption

HMRC: STRENGTHENING THE TAX AVOIDANCE DISCLOSURE REGIMES FOR INDIRECT TAXES AND INHERITANCE TAX The Law Society's response July 2016

TAX STRATEGY AND APPROACH TO TAX

JOSEPH GALLAGHER LTD CRIMINAL FINANCES ACT (ANTI-TAX EVASION) POLICY. Introduction

Anti-bribery Policy. This policy applies across the IGE Group to all directors and employees of IGE Group companies (IGE personnel).

STATUTORY INSTRUMENTS. S.I. No. 60 of 2017 CENTRAL BANK (SUPERVISION AND ENFORCEMENT) ACT 2013 (SECTION 48(1)) (INVESTMENT FIRMS) REGULATIONS 2017

Risk Management and Compliance

Small and Medium Sized Business (Finance Platforms) Regulations ABFA Policy Guidance

Principles and Practices of Financial Management (PPFM)

Tackling offshore tax evasion: A Requirement to Correct


Investigation into the acceptance of gifts and hospitality

Financial Crime Policy

About SSE. Foreword. Contents. Responsible tax core to a strategy for sustainable growth

Cotswold Way Challenge Conditions of Entry

STATUTORY INSTRUMENTS. S.I. No. 604 of 2017 CENTRAL BANK (SUPERVISION AND ENFORCEMENT) ACT 2013 (SECTION 48(1)) (INVESTMENT FIRMS) REGULATIONS 2017

Virgin Group Tax Strategy Statement

VODAFONE GROUP PLC TAX STRATEGY

UK Tax Strategy December 2017

Anti-bribery and corruption policy. The Perse School

Investigation into the Department s approach to tackling fraud

The UK s new corporate criminal offense. How adopting a robust risk-based approach could open the pathway for future global compliance

Tax avoidance: tackling marketed avoidance schemes. HM Revenue & Customs

STEP welcomes the opportunity to respond to the consulation paper published on 20 April 2016.

Working Together. Talking Points

Statement of Tax Principles & Strategy

Bates Wells Braithwaite response to HM Treasury Consultation Supporting the Employee-Ownership Sector

IMF-Japan High Level Conference, Tokyo, April 2013 Professor Judith Freedman, University of Oxford Law Faculty and Centre for Business Taxation

INSURANCE MANAGERS (CONDUCT OF BUSINESS) RULES 2014

BRIBERY ACT FREQUENTLY ASKED QUESTIONS (FAQs)

1 Introduction. 1.4 Our stated objectives for the tax system include:

LION RE:SOURCES UK LIMITED (the Company ) ANTI-BRIBERY AND CORRUPTION POLICY

DECLARATIONS OF INTERESTS AND POTENTIAL CONFLICTS OF INTERESTS POLICY. ENDORSED BY: Executive Team; Consultative Committee

Transcription:

BRITISH BUSINESS BANK BRITISH BUSINESS BANK TAX POLICY Version Date Author Description Approval Body Date Approved Date Issued V0.1 30 Oct 14 David Campbell Tax policy 1 Nov 14

Contents 2 Purpose... 3 3 BBB taxation policy... 3 4 Principles... 3 4.1 4.2 Managing Public Money... 3 The Code of Practice on Taxation for Banks... 3 5 Application of principles... 3 5.1 5.2 5.3 BBB s own tax affairs and investments... 4 Overseas elements... 4 BBB staff... 5 6 Governance... 5 7 Glossary... 5 2 Page BBB Tax Policy 20141101

2 Purpose The purpose of this Policy is to ensure that British Business Bank plc and its operating subsidiaries (together BBB ) manage their tax affairs in a way that: - Complies with all relevant taxation legislation and regulation, including the Code of Practice on Taxation for Banks; - Avoids compromising its reputation; and - Meets shareholder and wider government expectations and requirements in respect of taxation matters. 3 BBB taxation policy The BBB s taxation policy is to manage its activities and investments in accordance with the highest standards that are applicable to a government-owned, UK-based bank, and in accordance with the government s stated objectives on tax transparency and openness. 4 Principles 4.1 Managing Public Money In accordance with its Framework Agreement with BIS, BBB will comply with the principles of HMT s Managing Public Money (published July 2013, as amended or replaced from time to time). BBB recognises the guidance on taxation matters within Managing Public Money. In particular, it is noted that 5.6.1 of that publication states: 5.6.1 Public sector organisations should not engage in, or connive at, tax evasion, tax avoidance or tax planning. If a public sector organisation were to obtain financial advantage by moderating the tax paid by a contractor, supplier or other counterparty, it would usually mean that the public sector as a whole would be worse off thus conflicting with the accounting officer s duties. Thus artificial tax avoidance schemes should normally be rejected. It should be standard practice to consult HMRC about transactions involving non-standard approaches to tax before going ahead. 4.2 The Code of Practice on Taxation for Banks BBB will comply with HMRC s Code of Practice on Taxation for Banks dated 9 December 2009 and HMRC s Governance Protocol dated 26 March 2012 as amended from time to time (together the Code"). In accordance with the Code, BBB will: - Adopt adequate governance to control the types of transactions it enter into; - Not undertake tax planning that aims to achieve a tax result contrary to the intentions of Parliament; - Comply fully with all its tax obligations; and - Maintain an open, professional and transparent relationship with HMRC. 5 Application of principles The Business Bank will satisfy itself in each case arising that its actions are consistent with the purposes, tax policy and principles set out in sections A, B and C. To achieve this, it will adhere to standards including (but not limited to) those below. 3 Page BBB Tax Policy 20141101

5.1 BBB s own tax affairs and investments In view of the principles underlying the Code and the paragraph of Managing Public Money cited above, in relation to its own tax affairs and investments BBB will: - Abide by HMRC s published guidance and practice regarding acceptable tax structuring. In case of doubt, BBB will seek professional advice where necessary, and where appropriate, having taken advice, may seek guidance or clearance from HMRC. If HMRC indicates that it regards any proposed arrangements as outside the range of acceptable tax structuring, BBB will not enter into such arrangements. - Only enter into transactions and investments that produce tax results which are consistent with the underlying economics of the relevant arrangements. - Not engage in any tax structuring that does not support a genuine commercial purpose or whose sole or principal purpose is to save tax. - Carry out appropriate due diligence checks on any transaction or investment structure before making any investment. To the extent appropriate, BBB may: - Engage external advisers where necessary to advise on any material tax implications of the structure; - Require contractual protections to ensure that the principles set out in this Policy are adhered to on an ongoing basis; and/or - Require contractual remedies to ensure that BBB can, if necessary, exit the transaction if it becomes aware that a structure it is participating in involves tax evasion or tax avoidance. 5.2 Overseas elements Whilst the principal objective of BBB s activities is to facilitate financing to UK based smaller businesses, BBB will from time to time invest in structures that have an overseas element or co-invest alongside overseas investors. BBB will: - Subject to paragraph E, avoid investing in, or through any structure that includes, an entity resident in an offshore jurisdiction. For the avoidance of doubt, this does not preclude investments in, or structures that include, companies, partnerships, incorporated or unincorporated bodies or other form of legal entity resident within the EEA for tax purposes. - As appropriate, conduct due diligence on any counterparty, co-investor or recipient of BBB-sourced funds (domestic or overseas), paying particular attention to whether it is operating out of an offshore jurisdiction, engaged in any form of tax evasion or unacceptable tax structuring. (The phrase unacceptable tax structuring shall be construed in a manner consistent with this Policy). - Expect all counterparties to comply with the tax law in their country of incorporation and to be upfront and honest in their dealings with their applicable tax authorities. UK counterparties will be expected to comply with the requirements of the Disclosure of Tax Avoidance Schemes (DOTAS) rules and the General Anti-Abuse Rules (GAAR) as amended from time to time. 4 Page BBB Tax Policy 20141101

5.3 BBB staff BBB will ensure that contracts for the engagement of employees, contractors and board members follow the recommendations of HMT s publication Review of the tax arrangements of public sector appointees (published May 2012, as amended or replaced from time to time). In accordance with such recommendations: - Board members and senior officials with significant financial responsibility shall be on the BBB payroll, unless there are exceptional circumstances approved by BBB s Accounting Officer and the Principal Accounting Officer. - Engagements of more than six months in duration and for more than a daily rate of 220 shall include contractual provisions regarding the income tax and NICs obligations of the individual engaged. 6 Governance Transactions or investments should be referred first to the relevant Investment Committee for approval and if, any doubt remains following such referral, to the Board of BBB, in the following circumstances: - Where there is any doubt as to whether a proposed transaction or investment is appropriate from a taxation perspective; - Where due diligence checks suggest a proposed co-investor, counterparty or recipient of BBB-sourced funds is promoting or entering into tax evasion or unacceptable tax structuring schemes or is tax resident in an offshore jurisdiction or has a contentious or dubious history of tax compliance; or - Where BBB proposes a transaction or investment in, or through any structure that includes, an entity which is not subject to EEA taxation, or in structures that could be deemed novel, contentious or repercussive. - BBB will ensure that procedures are in place for the review of proposed and existing transactions to ensure compliance with this Policy. 7 Glossary Reference BBB BIS You/staff CAO EEA Meaning British Business Bank The Department of Business Innovation and Skills An employee, secondee or contractor working for BBB Chief Accounting Officer The European Economic Area 5 Page BBB Tax Policy 20141101