Issued by Mark Garrard, Chief Financial Officer. In accordance with the Finance Act 2016, Schedule 19, Part 2, Bertram Group publishes its tax strategy for the financial year ended 31 December 2019.
Objectives of Bertram Group’s tax strategy
The objective of Bertram Group’s tax strategy is to pay the correct amount of tax as it becomes due, to balance the need to build and maintain trust with stakeholders (including the relevant tax authorities) and to maximise the return for investors.
Bertram Group’s approach to its tax strategy is driven by the following objectives:
• Acting with honesty and integrity. Honesty and integrity are at the heart of our values. Our aim is to be trusted by all our stakeholders.
• Bertram Group will be transparent, proactive and open in its dealings with relevant tax authorities.
• Compliance with legislation. Our objective is to pay the right amount of tax and submit the correct information to the tax authorities at the right time.
• Fairness to all our stakeholders. Bertram Group pays all taxes that are required. We also have a duty to our shareholders and to our customers to pay only the tax that is required so that our shareholders receive a fair return and customers pay a fair price for the services that we deliver.
Bertram Group’s tax risk profile and management of tax risk
The tax risk profile of Bertram Group is considered relatively low for following reasons:
• The Bertram Group has subsidiaries domiciled in the UK, the Netherlands, Germany and France; however, circa 90% of sales are generated from its UK businesses. The Group is not subject to complex international tax structuring and significant intra group cross border transactions.
• The Bertram Group engages with professional advisors to ensure compliance with non-UK tax legislation and registrations.
• The Bertram Group’s corporation tax is low level complexity.
• The Bertram Group has no complex borrowing arrangements and therefore is not exposed to the tax risks associated with complex financing structures.
The Board are responsible for overseeing the Group risk management process and reviewing the risk register. This process incorporates tax risks. The Chief Financial Officer oversees a review of all business risks at least twice each year. Where risks are higher than deemed acceptable, mitigating actions are put in place to reduce the risk. This process, and its results, are reported to and reviewed by the Board.
Key roles, responsibilities and oversight
Ultimately responsibility for the tax strategy rests with the Board.
Tax planning and compliance is the responsibility of the finance function and the Chief Financial Officer is responsible for oversight of 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 compliance matters are delegated to the finance function. The finance team includes a range of staff with professional qualifications appropriate to the roles that they perform.
Systems and controls in place to manage tax risk
The Group has a range of systems and controls in place to ensure that all financial transactions are accurately reported, and the tax thereon is calculated correctly, including:
• As set out above, tax risks are monitored, and appropriate mitigating actions put in place.
• Only suitably qualified staff within the finance function take decisions regarding taxation.
• Documented policies are in place to help ensure that all staff are fully aware of the policies. These policies cover matters that might impact on taxation.
• All employment related payments are required to be made through the payroll.
• The Board receives and reviews the status of tax compliance and the outcome of any reviews performed by HMRC.
• External advice is sought from the professional advisors as required.
Bertram Group’s attitude to tax planning
The Group is committed to acting with honesty and integrity. The finance team who deal with tax planning and compliance are appropriately qualified professionals and the professional bodies to which they belong require a high standard of honesty and integrity.
The overriding requirement of Bertram Group’s tax strategy and policy is to comply fully with tax law, both in the UK and overseas. The Group aims to make timely and accurate tax returns and payments. Within this context, we aim to be fair to our stakeholders, such as customers and shareholders, by minimising the Group’s tax liabilities in accordance with legislation. Whilst seeking to do so, we seek to make use of appropriate reliefs permitted by legislation.
The Group’s policy is not to take an aggressive interpretation of tax legislation or use artificial tax avoidance schemes. The Bertram Group does not perform tax planning where the main purpose is to gain a tax advantage.
To support the Group in ensuring that it has interpreted tax law correctly, it seeks advice from accounting firms, legal firms and tax counsel as appropriate.
The level of risk in relation to taxation that Bertram Group is prepared to accept
Bertram Group’s policy is to accept a low level of risk regarding taxation, both in the UK and overseas. This is achieved by the policies set out above.
As in every organisation there is a cost to establishing and maintaining systems and control to ensure the accuracy of recording normal transactions. The Group’s systems are designed to ensure that the Board have confidence in the reasonable, but not absolute, accuracy of transactions.
Decisions on tax planning are taken at a senior level and agreed by the Chief Financial Officer. Individuals are not given delegated responsibility which would allow them to set their own level of risk which could be taken in tax planning.
It is Bertram Group policy that the Board should be involved in making decisions where there are any doubts over how to apply the tax strategy to a specific set of circumstances.
Bertram Group’s approach towards its dealings with HM Revenue & Customs (“HMRC”)
An important part of the Group’s tax strategy is the maintenance and development of a strong, proactive working relationship with HMRC. It is Group policy to be transparent with HMRC.