This document, approved by the board of Optionis Limited, sets out the Group’s approach to conducting its tax affairs and dealing with tax risks, and is made available to all of the Group’s stakeholders. This document will be periodically reviewed by the Senior Accounting Officer and any amendments will be approved by the board of Optionis Limited. It is effective for the year ended 31 October 2018, and will remain in effect until any amendments are approved by the board of Optionis Limited.
This tax strategy document is compliant with the requirements of Schedule 19 of Finance Act 2016.
The Optionis Group is committed to:
Approach to risk management and governance
Our Chief Financial Officer (who is also our Senior Accounting Officer) delegates the day to day management of our tax affairs, through the operation of our tax function. Individual roles and responsibilities are clearly defined and our managers are authorised to make decisions and sign filings and other documents in relation to our tax affairs, within specified thresholds. There is a process to ensure that decisions are taken at appropriate levels across the Group and at a Company level.
Managing the Group’s own tax affairs is a complex process across many functional areas of the business and as such there will inevitably be risks of error or omission within those processes (Tax Risks) which may result in the incorrect application of tax rules or calculation of tax returns. Eliminating tax risks entirely is impossible, therefore the Group’s attitude towards the level of control required over the processes designed to reduce these Tax Risks is driven by the likelihood of occurrence and scale of impact of each Risk.
The identified Tax Risks are then assessed on a case by case basis, allowing the Group to arrive at well-reasoned conclusions on how each individual Risk should be managed. Where there is uncertainty in how the relevant tax law should be applied, external advice may be sought to support the Group’s decision making process.
When reviewing the Tax Risks associated with a specific decision or action, the Group ensures that the following are considered:
Attitude towards tax planning
The Group’s tax planning aims to support the commercial needs of the business by ensuring that the group companies affairs are carried out in the most tax efficient manner whilst remaining compliant with all relevant laws. The tax function is therefore involved in commercial decision making processes and provides appropriate input into business proposals to ensure a clear understanding of the tax consequences of any decisions made.
Internal governance is not prescriptive on the levels of acceptable risk but, in practice, where there is a material doubt as to the tax treatment of any particular transaction or where the tax guidance is unclear or the Group does not feel it has the necessary expert knowledge to assess the tax consequences adequately, external advice may be sought to support the Group’s decision making process and/or the Group will seek to resolve the uncertainty by dialogue with tax authorities.
We do not enter into artificial arrangements in order to avoid taxation nor do we utilise companies incorporated in “tax havens” as a means of reducing the Group’s tax liabilities.
As at 31 October 2018, all group companies are incorporated in England and are therefore subject to full UK tax.
Approach towards dealings with HMRC
The Group is committed to the principles of openness and transparency in its approach to dealing with HMRC, and in particular the Group commits to:
Signed on behalf of Optionis Limited
Kevin J Budge BA FCA
Chief Financial Officer (and Senior Accounting Officer)