The objective of CVS’s tax strategy is to pay the correct amount of tax as it becomes due, to balance the need to build and maintain trust with stakeholders (including the UK Government and relevant tax authorities) and to maximise the return for investors.
CVS’s approach to its tax strategy is driven by the following objectives:
The tax risk profile of CVS is considered relatively low for following reasons:
The Board and the Group Internal Audit Manager, who reports to the Chairman of the Audit Committee, are responsible for overseeing the Group risk management process. This process incorporates tax risks. The Internal Audit Manager oversees a review of all business risks with relevant divisions and staff at least twice each year. Where risks are higher than deemed acceptable, mitigating actions are put in place to reduce the risk. This process, and its results, are reported to and reviewed by the Audit Committee.
Ultimately responsibility for the tax strategy rests with the Board. It is reviewed annually by the Group’s Audit Committee.
Tax planning and compliance is the responsibility of the finance function of CVS and the Group Finance Director (who is a Board member) is responsible for oversight of Group’s tax strategy and policies.
Tax strategy and policy issues are assessed on a case by case basis by the Group Finance Director in accordance with this strategy.
Day-to-day tax compliance matters are delegated to the finance function. The finance function has a broad range of experience both within CVS and in other large organisations. The team includes a range of staff with professional qualifications appropriate to the roles that they perform.
The Group has a range of systems and controls in place to ensure that all financial transactions are accurately reported and the tax thereon is calculated correctly, including:
The Group is committed to acting with honesty and integrity. The finance team who deal with tax planning and compliance are appropriately qualified professionals and the professional bodies to which they belong require a high standard of honesty and integrity.
The overriding requirement of CVS Group’s tax strategy and policy is to comply fully with tax law, both in the UK and overseas. The Group aims to make timely and accurate tax returns and payments. Within this context, we aim to be fair to our stakeholders, such as customers and shareholders, by minimising the Group’s tax liabilities in accordance with legislation. Whilst seeking to do so, we seek to make use of appropriate reliefs permitted by legislation.
The Group’s policy is not to take an aggressive interpretation of tax legislation or use artificial tax avoidance schemes. CVS Group does not perform tax planning where the main purpose is to gain a tax advantage.
To support us in ensuring that we have interpreted tax law correctly, we seek advice from large accounting firms, legal firms and tax counsel as appropriate. Equally to ensure that we take advantage of all tax opportunities which are open to us we work with professional advisors to understand changes in legislation.
CVS Group’s policy is to accept a low level of risk with regard to taxation, both in the UK and overseas. This is achieved by the policies set out above.
As in every organisation there is a cost to establishing and maintaining systems and control to ensure the accuracy of recording normal transactions. The Group’s systems are designed to ensure that the Board have confidence in the reasonable, but not absolute, accuracy of transactions.
Decisions on tax planning are taken at a senior level and agreed by the Group Finance Director. 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 CVS Group policy that the Board should be involved in making decisions where there are any doubts over how to apply the tax strategy to a specific set of circumstances.
An important part of our tax strategy is the maintenance and development of a strong, proactive working relationship with HM Revenue & Customs (“HMRC”). It is CVS Group policy to be transparent with HMRC.
