Tax strategy statement
This document sets out the tax strategy, in relation to UK taxation, of CVS Group plc and the group of UK companies held through its wholly owned subsidiary, CVS (UK) Ltd (“CVS”).
CVS overall tax strategy
The objective of CVS’s tax strategy is to:
- Pay the right amount of tax at the right time.
- Maintain an open and robust relationship with HM Revenue & Customs (“HMRC”).
- Maximise the return for investors.
- Always act with honesty and integrity. Honesty and integrity are at the heart of our Group’s cultures and values.
CVS’s approach to risk management and governance arrangements in relation to UK taxation
Key roles, responsibilities and oversight
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 acts as Senior Accounting Officer 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 is predominantly UK based with only a small proportion of our business in overseas jurisdictions. Therefore, the Group does not have complex international tax structuring or significant cross border transactions.
- The Group has no complex borrowing arrangements and therefore is not exposed to the tax risks associated with complex financing structures.
- The Group does not enter into artificial tax arrangements.
Systems and controls in place to manage tax risk
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:
- Documented policies available on the Group’s intranet that encompass areas that may impact on taxation.
- Robust process for preparation and review of tax returns and filings.
- Accounting, tax and payroll processing in the UK is centralised, ensuring that appropriate expertise is concentrated in one place.
CVS’s attitude to tax planning
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.
The level of risk in relation to taxation that CVS is prepared to accept
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.
CVS’s approach towards its dealings with HMRC
The Group is committed to developing and maintaining an open and constructive working relationship with HMRC. It is CVS Group policy to be transparent with HMRC.
This statement is made pursuant to the requirements of Schedule 19 of Finance Act 2016 in respect of the year ending 30 June 2020. It was approved by the Board of Directors on 25 June 2020.