This document sets out the tax strategy of CVS Group plc and its wholly owned subsidiaries (“CVS” or “the Group”) in the UK, and other territories as applicable.
The objective of CVS’s tax strategy is to:
Ultimately, responsibility for the tax strategy rests with the Board. The tax strategy is approved by the Board.
Responsibility for tax strategy, tax policies, management of tax risk, tax planning and compliance rests with the Chief Financial Officer at Board Level.
The Chief Financial Officer is the appointed Senior Accounting Officer in accordance with the UK’s Senior Accounting Officer legislation, and as part of this role establishes and maintains appropriate tax accounting arrangements, and certifies this to HMRC annually.
Day-to-day tax responsibility for the operation of tax rests with the Finance Team, including the Group Tax Manager. The team includes a range of staff with experience and professional qualifications appropriate to the roles that they perform.
The Audit Committee are responsible for ensuring the Group’s financial reporting, including tax, is appropriate through the work performed by the Internal Audit Function.
The Internal Audit Team, who report to the Chairman of the Audit Committee, are responsible for overseeing the Group’s overall risk management process. This process incorporates tax. The tax risks are monitored through the use of a tax risk register. Where risks are higher than deemed acceptable, based on principles of reasonable care and materiality, mitigating actions are put in place to reduce the risk.
The risks are quantified using a consistent risk approach used for the overall Group risk register. The overall risk management process provides an escalation framework and overall visibility and oversight of the risks by the Audit Committee. The tax risk profile of CVS is not considered inherently high for following reasons:
The Group has established processes and controls in place to ensure that all transactions are accurately reported, the tax thereon is calculated correctly, and returns are submitted on time, including but not limited to:
The Group is committed to acting with honesty and integrity.
The Group aims to meet all of its statutory obligations and ensure that the right amount of tax is paid at the right time, and that returns are made on timely basis.
Within this context, the Group aims to be fair to our stakeholders, such as customers and shareholders, by ensuring the Group’s activities are carried out in a tax efficient manner and any tax planning is undertaken in this context.
The Group’s policy is to not undertake an aggressive interpretation of tax legislation or use artificial tax avoidance schemes. The Group does not perform tax planning where the main purpose is to gain a tax advantage, all transactions must have a business purpose. The Group applies relevant tax laws in a reasonable way and in the spirit they were intended, such as making use of the appropriate reliefs and exemptions permitted by legislation.
Matters that require judgement are reserved for senior members of the finance team with a professional qualification. All areas of judgement are ultimately reviewed by the Chief Financial Officer.
To support the Group in ensuring we have interpreted tax law correctly, have understood the tax reliefs and exemptions available to us, or where there is significant uncertainty or complexity, we may seek advice from reputable external professional firms.
CVS Group’s policy is to only accept a low level of risk with regard to taxation.
Decisions on tax planning are undertaken only at a senior level and as agreed by the Chief Financial Officer. Individuals are not given delegated responsibility which would allow them to set their own level of risk which could be taken in tax planning.
It is the Group’s policy that the Board should be involved in making decisions where there are any doubts over how to apply the tax strategy.
The Group is committed to developing and maintaining an open and constructive working relationship with HMRC and the tax authorities in each jurisdiction in which it operates. It is CVS Group policy to be transparent with HMRC and all other tax authorities.
Whilst this is a global tax strategy, this statement is made pursuant to the requirements of the UK legislation, Schedule 19 of Finance Act 2016, in respect of the year ending 30 June 2022. It was approved by the Board of Directors on 23 March 2022.
