BrightHouse Group Tax Strategy 2019-20
This document sets out the strategic tax objectives for the BrightHouse Group (BrightHouse). While the group recognises its legal responsibilities to pay the correct amount of tax, the tax strategy is designed to support the strategic and commercial objectives of the group in a way that also enhances its reputation and commercial value. Also, in considering the tax strategy, the group also considers the companies legal responsibility to act in the interests of its shareholders.
BrightHouse recognises that reputation and integrity are a key to success in the retail space which the group occupies and sees the tax strategy as a key component in maintaining this reputation.
To achieve this, the tax team work with business partners throughout the group to ensure that:
The tax strategy is adopted and followed consistently across the group; and
The tax strategy is aligned with the overall strategy including corporate governance, risk management, quality assurance and fraud risk management.
BrightHouse is a business which includes a retail operation, financial services, insurance services and warranty guarantees including repairs (known as BrightCare). This means its tax affairs are complex and any tax strategy needs to reflect this.
The payable and reportable UK taxes to which this strategy applies are:
The tax strategy also applies to other tax reporting activities including:
Management of tax risks
BrightHouse objective is to pay the right amount of tax in the right place at the right time. Included in this objective is to be compliant with all laws and regulations including tax legislation relevant to the group.
This objective is achieved by the evaluation, and monitoring of all aspects of the BrightHouse business and the UK tax environment. This is managed in a risk management framework which includes tax risk assessments undertaken as part of the Senior Account Officer regulations and the Criminal Finance Act relating to tax evasion.
This risk management framework acts to reduce tax risks and exposures throughout the business. All tax risks are managed by the BrightHouse tax team with oversight from the Chief Financial Officer on behalf of the board.
As part of the governance process, regular reports are made to the Audit committee and the Board. The Audit Committee and the Board give guidelines to the business on how the BrightHouse UK tax risk will be managed.
These guidelines are designed to maintain the reputation of the business by keeping BrightHouse compliant and with a low UK tax risk. Any major transaction will be reviewed in advance for tax risks. If there is a complex risk with uncertain outcomes or there is a risk of a significant tax liability, third party advisors will be consulted.
The group aims for certainty and transparency on all its UK tax risks and obligations, and works towards resolving any uncertain positions.
The Attitude to Tax Planning
The main objective of the tax strategy of the group is to be compliant with all laws and regulations including tax legislation relevant to the group. This involves disclosing all relevant facts and circumstances to the tax authorities and operating within the framework of UK legislation and UK case law.
FCA compliance requires that the business takes a low risk approach to tax planning and any tax issues arising from existing and new tax legislation.
However, BrightHouse regards all taxes as a commercial cost of doing business and will seek to minimise tax cash outgoings, tax risk exposures and liabilities within this framework.
Advice is regularly sought from third party advisors and with our HMRC team as to the most efficient way of meeting our tax payment and compliance responsibilities and for any other significant tax risk.
BrightHouse group seek to operate a tax strategy leading to being considered a low tax risk to the UK authorities
Governance is provided by committees of non executive directors (particularly the Audit committee) and the Board. The attitude of these governance panels which reflect the views of stakeholders is risk averse and concerned with the reputation of the group. This leads to a low risk approach to tax planning.
Working with HMRC
BrightHouse engages with HMRC with honesty, integrity, and in a spirit of cooperation. An open and constructive relationship is sought with HMRC, and particularly with our assigned HMRC team. There is continuous communication both in terms of requests for advice and providing information about the business in a courteous and professional manner.
Wherever possible information and discussions take place in real time. It is always our preference to resolve matters in a spirit of cooperation and negotiated agreement through transparent and active discussion.