1. Introduction
This strategy applies to all UK entities within the Sopra Steria Group (hereafter referred to as “Sopra Steria UK”) for the financial year ended 31 December 2018. This strategy document is intended to comply with the requirements of Schedule 19 of the Finance Act 2016 and will be reviewed on an annual basis and updated where necessary.
2. Overall strategy
Sopra Steria UK’s overall tax strategy is based on the following principles:-
- Compliance with all applicable laws, rules, regulations and disclosure requirements
- Ensure appropriate diligence and care in the management of all risks associated with tax matters
- Utilise available tax reliefs where applicable but with due care to the Government’s policy intentions behind the tax reliefs
- Develop and maintain open relationships with HMRC
3. Compliance
Compliance for Sopra Steria UK means paying the right amount of tax at the right time and involves disclosing all relevant facts and circumstances to HMRC. This compliance principle is fully supported by the UK executive board and involves constant dialogue with, and support to, the UK tax team charged with implementing this policy.
4. Managing tax risks
Sopra Steria UK remains committed to maintaining its existing low tax risk rating with HMRC.
Given the scale of our business and the complexity and volume of our tax obligations, risks will inevitably arise from time to time in relation to the interpretation of tax law and the nature of our compliance arrangements. Sopra Steria UK proactively seeks to identify, evaluate, manage and monitor these risks to ensure they remain in line with the group’s risk appetite. Where there is significant uncertainty or complexity in relation to a risk, Sopra Steria UK will typically seek appropriate external advice to de-risk the position.
5. Attitude to tax planning
Any tax planning undertaken will have commercial and economic substance and will have regard to the potential impact on our reputation and broader goals. Sopra Steria UK will not undertake planning that is contrived or artificial and will not implement or utilise tax avoidance strategies that exploit gaps and / or mismatches in tax rules to artificially shift profits to low tax locations.
Where Sopra Steria UK is looking to utilise tax incentives or opportunities these will only be considered where it is clear that their use falls within the Government’s broad aim / intention for these tax reliefs.
6. Working with HMRC
Sopra Steria UK will endeavour to maintain open, honest, transparent and cordial relationships with HMRC (or any taxation authorities that it may deal with). The tax department will operate on the basis of a full and timely disclosure of our transactions to the extent required by applicable tax law. Sopra Steria UK will try to ensure that HMRC is kept aware of significant transactions and changes in the business and seeks to discuss any tax issues arising at an early stage.
Where disputes between Sopra Steria UK and HMRC do arise and it is necessary to undertake litigation to defend Sopra Steria’s position this will only be done after all alternatives have been explored and have been discounted. Litigation regarding taxation matters will only been undertaken with the express approval of the wider Sopra Steria Group and will be pursued in a professional manner without compromising the broader foundation of the relationship.
This strategy is aligned with our Ethics Code and is approved, owned and overseen by the UK Executive Board.