Slater and Gordon UK Holdings Limited and its subsidiaries (“Slater and Gordon” or “the Group”) issue this statement of tax policy to comply with Paragraph 16 and Paragraph 25 of Schedule 19 of Finance Act 2016.
This Tax Strategy applies to the 18 month period from 1 July 2017 to 31 December 2018, following a change in the Group’s accounting reference date.
The key taxes for the Group are:
- Corporation Tax with respect to the various Group member companies.
- Income Tax for the Limited Liability Partnership.
- VAT as the Group is VAT-registered and (with respect to a very high proportion of its turnover) supplies VAT standard-rated services to UK customers.
- Payroll taxes (PAYE and NICs) given the workforce size (some 2,700 at the time of publication).
About the Group
We are one of the UK's largest and best-known consumer law firms, with offices in locations across England, Scotland and Wales as well as in Malta.
We provide a wide range of specialist consumer legal and complementary services.
Mission, Values and Corporate Social Responsibility
Our mission is to provide people with easier access to world-class consumer legal services. Our work is underpinned by our values, as stated on our website, and our Tax Strategy is consistent with these values.
We strive to support the community and economy by abiding tax laws and regulations while balancing shareholder interests and reputation.
Our Tax Strategy is also consistent with our approach to corporate social responsibility – to have a positive economic, environmental and social impact that goes beyond our core activity.
Risk Management and Governance
The Group manages tax risk through a mix of in-house staff and external tax advisers.
We focus on minimising risk of tax compliance failure to ensure the Group avoids incurring any costs of non-compliance across all taxes.
The Group Chief Financial Officer has ultimate responsibility for tax, reporting to the main board of directors and shareholders and delegating this on a day-to-day basis to the Head of Tax.
The Head of Tax works with Finance Directors of the individual operations around the taxes listed above. External advisers support these processes.
We outsource preparation of Corporation Tax and Income Tax returns and statutory tax reporting work to a specialist provider, which is overseen and reviewed by the Head of Tax.
Indirect tax and Payroll tax processes are regularly reviewed and, supported by professional advisers.
Direct tax returns are prepared by an external specialist, and reviewed by the Head of Tax and also by the Finance Director responsible for the specific company.
VAT returns are prepared by each business unit with a separate VAT registration. Technical issues are referred to the Head of Tax and an external VAT specialist retained to resolve VAT issues. HMRC queries are also escalated to the Head of Tax.
Payroll taxes are dealt with by an in-house team, supported by the Head of Tax who advises on specific technical issues, such as redundancy or relocation expenses. An external specialist supports the Group’s internal team.
Any corporate activities such as transfers of assets between companies, changes in capital or changes in group structure/corporate ownership are reviewed by the Head of Tax to ensure any consequential tax compliance obligations are identified and action is taken to fulfil these in terms of tax filings or disclosures.
The Group is within the Senior Accounting Officer regime and reports annually to HMRC accordingly. Commentary is included in that report to summarise developments and improvements made in our tax control environment since the previous year’s filing.
Level of risk in relation to UK taxation that the Group is prepared to accept
The Group has no defined level of ‘acceptable risk’, and a low appetite for tax risk.
A key objective in our work to return to profitability is to minimise the risk of interest and penalties relating to tax, especially given current operating losses and the consequential low direct tax burden.
The Group makes generally non-VAT-exempt supplies to UK customers and views VAT as a key area where risk of non-compliance could result in significant cost. We ensure we seek regular input from advisers on technical issues.
The Group’s workforce of circa 2,700 at the time of publication means that there is a significant payroll tax obligation, but remuneration arrangements are straightforward and specialist advisers assist in any areas of doubt.
We have an economic, environmental and social impact that goes beyond our core activity, and the Slater and Gordon name is well-known amongst consumers. We want to maintain our reputation as a trusted adviser and our attitude to tax planning reflects this.
We do not want to put in place tax arrangements that are contrived or artificial, especially as this could damage our position as a trusted legal adviser to our customers. While we may take advantage of opportunities to arrange tax affairs efficiently, we do not implement arrangements where there is any ambiguity over the correct tax treatment.
Our approach seeks to balance the interests of shareholders with customers, tax authorities and regulators, as well as the local communities in which we operate.
We use advisers primarily to manage risk and to ensure we are aware of the full taxation implications arising from transactions. The Head of Tax works with advisers, oversees their input, and ensures advice given is appropriate to our attitude to tax planning. We work with advisers over an extended period, so they know our business and appetite for tax planning.
Dealings with HMRC
We strive for an open and collaborative relationship with HMRC departments which deal with our tax affairs.
The Group strives to ensure all filings are submitted on time and provides HMRC with clear and adequate levels of detailed disclosures so that HMRC can fulfil its obligations to review our affairs.
Voluntary disclosures have been made previously, which indicate proactive management of tax processes. In any enquiry situation, we will seek to agree a pragmatic approach with HMRC.