Stemcor Global Holdings Limited (SGHL) Group – Tax Strategy
Approach to Tax Matters
- The Stemcor Group is committed to complying with the tax laws in the jurisdictions in which it operates and strives to pay taxes and fulfil compliance obligations on an appropriate and timely basis.
- The Stemcor Group’s decisions are primarily driven by commercial considerations and business realities; tax considerations are secondary to these commercial transactions.
- The Stemcor Group may optimise its tax position to maximise shareholder value only in accordance with the tax legislation and relevant case law, as well as the Group’s risk appetite.
Roles and Responsibilities for Tax Affairs
The SGHL Board of Directors is responsible for approving the overall tax strategy for the group, as put forward by the Group CFO. The Board also maintains an interest in the ongoing tax risk management tax compliance and tax planning within the Group.
Overall executive responsibility for taxation in the group sits with the Group CFO, with support from internal and external tax specialists. These responsibilities include maintaining an overview of the tax activities and controls in the Group’s operations across the world, overseeing tax compliance and tax advisory for the UK companies and providing advice on the tax affairs of companies within the Group. The Group CFO is also registered at Her Majesty’s Revenue & Customs (HMRC) as the Senior Accounting Officer for all the Group’s UK companies.
For subsidiaries outside the UK, the local Business Unit Financial Controller has responsibility for tax compliance in their country. The local head of finance achieves this through a combination of their own team as well as input from local third party tax advisors and the central tax team, as necessary.
Management of Tax Compliance and Risks
The Stemcor Group’s tax compliance and tax risks are managed by the Group CFO, supported by internal and external specialists. The Stemcor Group has a robust Risk Management Framework in order to manage and mitigate the full range of risks the Group faces, including tax risks. The SGHL Board of Directors retains ultimate responsibly for the Group’s regulatory compliance and risk management, however day to day oversight of risk management has been delegated to the Group’s Risk Management Team (RMT). Tax compliance is delegated primarily to the central tax team, with material risks identified, or decisions to be made, routed up to the SGHL Board via the RMT.
The Group is prudent about the level of tax risks deemed to be acceptable, is committed to paying an appropriate amount of tax at the appropriate time with a view to minimising interest charges.
The Group has a central tax team which collaborates with the business units within the Stemcor Group and is actively involved in any material corporate transactions which may have a tax impact, providing advice and guidance to maintain compliance. The Group ensures that it’s tax team is appropriately qualified with sufficient understanding of the business to provide support, and to draw conclusions on the facts and risks involved. The Group’s central tax function, and local Financial Controllers, are supported by external third-party tax advisors, whose services are called on in a variety of areas. All tax advisors to the Group and its business units are high-quality, professional, and well renowned advisory companies.
Dealings with Tax Authorities, including HMRC
The SGHL Group aims to be transparent and open in its dealings and correspondence with all international tax authorities which have jurisdiction over relevant parts of the Group’s corporate affairs. HMRC is the primary tax authority with which the Group has dealing and it is our policy to take a collaborative approach when discussing tax compliance, risks, events, and interpretations of the law, with HMRC. The Group keeps HMRC informed of all relevant significant business transactions and seek clearances on material and/or significant judgements, as appropriate.
The SGHL Group regards the publication of this tax strategy as complying with the duty under paragraph 16(2) of Schedule 19 of the Finance Act 2016 to publish the group tax strategy for the financial year ending 31 December 2018.