AURELIUS UK tax strategy

Scope

This strategy applies to the UK investments which consider it as being compliant with the duties under paragraph 19(2) of schedule 19 to the Finance Act 2016 and under paragraph 22(2) of schedule 19 to the Finance Act 2016. This strategy is published by Aurelius Crocodile Ltd, and on behalf of the UK investments, and applies from the date of publication until it is superseded.

 

The references to UK tax refer to the taxes and duties set out in paragraph 15(1) of schedule 19 to the Finance Act 2016 which includes income tax, corporation tax, pay as you earn, national insurance contributions, value added tax, insurance premium tax, stamp duty and stamp duty land tax. The references to tax refer to UK tax, and to all corresponding worldwide taxes and similar duties for which the group has legal responsibilities. The references to the UK investments refer to the UK companies held by Aurelius Investment Lux One Sarl.

 

Aim

Aurelius Investment Lux One Sarl, together with its UK investments, are committed to complying with tax filing, reporting and payment obligations (wherever operating) and to have a constructive and transparent relationship with the tax authorities.

 

Governance

The oversight of the tax affairs for the UK investments, including (but not limited to): i) the tax governance framework; ii) the management of tax risks; and iii) the handling of the tax filing and payment obligations; is assigned to the local management of the companies.

 

The local management shall also inform the chief financial officer and / or the tax and legal team of Aurelius Investment Lux One Sarl regarding any material adverse tax events which arise at the level of each UK investment.

 

The monitoring of the overall tax aspects that impact the UK investments (such as country by country reporting, group tax relief, corporate interest restriction, etc) is assigned to the group tax director. The board of Aurelius Investment Lux One Sarl are advised of key tax events, which allows board members to be involved in the tax affairs at the overall group level, ensuring that the UK investments are compliant with responsibilities.

 

The key principles which are adhered to when considering tax are as follows:

 

Governance framework: At the level of the respective UK investments, the responsibility for the tax affairs sits with appropriately qualified and experienced teams, consisting of finance and / or tax professionals. At the level of Aurelius Investment Lux One Sarl, the UK investments are supported by an experienced Aurelius tax team and by local tax advisers. The management of the group will continue to develop with the structure and will be reviewed at suitable intervals to ensure it remains appropriate to the business / external tax environment.

 

Risk management: We are aware that risks associated with compliance and reporting failures, as well as risks associated with transactions and reorganisations within the group, may arise given the scale and nature of the UK investments. In cooperation with external tax advisors, local management and management of Aurelius Investment Lux One Sarl, there is proactive identification, management and monitoring of tax risks. The oversight of the risk areas is supported by the local tax teams (where available), local management, the tax and legal teams for Aurelius Investment Lux One Sarl and external tax advisers.

 

Tax planning: Aurelius Investment Lux One Sarl, together with its UK investments, maintain a strong commercial focus and, as part of its duty to its stakeholders to mitigate unnecessary costs, there are claims for tax reliefs / allowances in the manner intended by the tax authorities. The tax planning undertaken has commercial and economic substance (with no engagement in artificial tax arrangements). There are external advisers engaged to provide technical expertise when necessary to assist tax planning (to the extent required).

 

Acceptable risk: The level of risk which Aurelius Investment Lux One Sarl, and the UK investments, accept in relation to UK tax is consistent with its overall objective of complying with regulatory and other obligations, and its overall objective to act in a way which supports its reputation as a responsible corporate resident.

 

Tax authorities: The UK investments work in partnership with HMRC to meet statutory and legislative tax requirements. The UK investments aim to have an open and transparent relationship with HMRC, on current, future and past tax risks across all taxes, disclosing all relevant facts and circumstances and seeking to resolve any disputed matters through proactive discussion with HMRC.