Global Tax Strategy
We (the Brewin Dolphin Group) are one of the UK’s leading providers of personalised wealth management services offering investment management and financial planning services primarily to private clients, trustees and intermediaries.
Our approach to risk management and governance arrangements:
Tax risk is the risk that our tax reporting returns or liabilities are inaccurate or incomplete, potentially leading to under or over collection or payment of tax, exposing us to tax authority sanctions as well as potential damage to our reputation. We are subject to the following principal taxes:
- corporation tax on the profits of our business;
- employer social security contributions on employment costs; and
- value added tax (or its equivalent) on relevant services.
We also facilitate the withholding and payment of income tax and social security contributions from employee remuneration and stamp duty from client trading activity.
We manage tax risk within our group wide risk management and governance framework:
- our Board is accountable for risk management and ensures that an effective Risk Management Framework (RMF) is in place, which encompasses tax risk.
- we operate an industry standard “three lines of defence” risk management model. Our first line of defence, and day to day responsibilities for the implementation of the group’s tax strategy rests with the group tax team and operational teams with tax responsibilities within the business. Our tax function, owns and assesses tax risk
- via an annual risk and control self-assessment. The tax function also promotes a culture of good governance, open communication and compliance and its key objective is to ensure that all tax returns, reports and payments are accurate and complete to the best of our knowledge and filed on a timely basis.
- where tax risk resides in operating functions across the business, similar risk and control self-assessments are conducted and where key risks are identified, controls are implemented and processes put in place to mitigate those risks.
- our risk and compliance function is the second line of defence, providing oversight and challenge group-wide, with any material issues being reported through both our executive and non-executive committee structure.
- we have processes and procedures in place to mitigate the risk, or risk of facilitation, of tax evasion.
- Internal audit periodically review the processes and risk governance arrangements within the Group, providing an independent, objective assurance function. This forms our third line of defence, with audit reports provided directly to the Board Audit Committee.
Risk appetite – the level of risk the Group is willing to accept:
Our appetite for tax risk is low. Our business model and operating structure is straightforward and not subject to significant judgement in the application of tax law. We do not seek to artificially manipulate our business affairs in order to unreasonably minimise our tax liabilities and aim to pay the right amount of tax in accordance with the spirit of the law in all jurisdictions.
The Group’s attitude to tax planning:
While we will run our business in a cost effective manner in line with our obligations to our shareholders and clients, in terms of tax, we will only utilise legitimate tax reliefs for the purposes for which they were intended by Parliament. We do not:
- engage in aggressive tax planning;
- seek to structure transactions in an artificial manner whereby results are inconsistent with the underlying economic consequences; or
- promote tax avoidance or condone abusive tax practices which would contravene our ethics and culture or the law.
We believe in safeguarding our reputation and our relationships with clients, shareholders and tax authorities alike and we are not subject to undue shareholder influence.
We will seek external tax advice in certain situations, for example:
- in respect of large, one off transactions such as business acquisitions or disposals, to ensure that we do not suffer any unforeseen or unreasonable tax outcomes;
- in areas where we may have insufficient internal expertise; and
- as a second opinion in cases where we believe there is uncertainty with respect to the application of tax law, although we may also approach HMRC directly, to seek clarity or obtain clearance.
Our approach to dealings with HMRC:
- Our objective is to build a stable, transparent and professional working relationship with HMRC and other tax authorities.
- We seek to have a constructive relationship with HMRC, through regular meetings and communication in respect of developments in our business, current, future and retrospective tax risks, and interpretation of the law in relation to all relevant taxes. We value the fact that we have a direct Customer Compliance Manager with whom we can proactively engage in dialogue.
- Any inadvertent errors in submissions made to HMRC are fully disclosed as soon as reasonably practicable after they are identified. We take a proactive approach and take appropriate action in the event we discover errors or omissions; implementing remediation as quickly as is reasonably achievable and putting in place measures and controls to prevent recurrence.
Brewin Dolphin Holdings PLC regards the publication of the information set out above as complying with the duty under paragraph 16 of Schedule 19 of the Finance Act 2016 (duty to publish a tax strategy).