This UK Tax Strategy sets out the approach of the Williams Lea Tag Group (the WLT Group) to risk management and governance arrangements in relation to UK taxation. It applies to all UK entities in the WLT Group within the charge to UK Corporation Tax and covers the attitude towards tax compliance, tax governance, tax planning and tax risk management as well as the approach to dealing with the UK tax authorities (HMRC).
The publication of this UK Tax Strategy complies with the requirements of the Finance Act 2016 Schedule 19 paragraphs 19(2) and 19(4) for the financial year ending 31 December 2017 and remains in force from the date of publication until it is superseded.
In November 2017, the WLT Group was acquired by Advent International, a global private equity investor. The UK operations of the WLT Group are fundamentally unaffected by this change.
Approach to Tax Risk Management and Tax Governance
As a multinational organisation, the WLT Group is exposed to a variety of tax risks. The WLT Group looks to manage tax risks in a similar way to other risks in the WLT Group.
The Finance function is responsible for monitoring tax risks within the business and internal controls are put in place to identify, quantify and manage those risks. Day to day management of the WLT Group’s tax affairs is delegated to the Group Head of Tax, a senior member of the Finance function who reports directly into the Group Chief Financial Officer (“GCFO”). The GCFO is the Board member with executive responsibility for tax matters. Ultimate responsibility for tax risk management and tax governance rests with the WLT Group Board.
The WLT Group is committed to full compliance with all statutory tax requirements and full disclosure to relevant tax authorities. The WLT Group’s tax affairs are managed in a way which takes into account the group’s wider corporate reputation in line with the group’s overall high standards of governance.
Attitude Towards Tax Planning
The WLT Group understands its responsibilities in complying with all relevant tax legislation and regulations in every country in which it operates. The WLT Group reserves the right to structure its affairs in a tax efficient manner and to utilise tax reliefs and incentives in accordance with intended government policy objectives. The WLT Group does not enter into wholly artificial structures or transactions which serve no commercial purpose other than to avoid tax.
All WLT Group employees are subject to the Code of Conduct provided to them when joining the business and this is available on the employee intranet.
External advice may be sought in relation to any area of taxation, including tax compliance processes, tax structuring and tax planning.
Level of Acceptable Tax Risk
There are no formal levels of acceptable tax risk. Tax risks are managed on the same basis as other risks within the business. The WLT Group is fully committed to complying with all tax laws and regulations in each of the countries in which it operates.
Approach towards Dealings with HMRC
The WLT Group seeks to establish and maintain an open and constructive relationship with HMRC. The WLT Group is committed to compliance with all statutory obligations and undertakes to provide full disclosure of all relevant matters. Where appropriate, the WLT Group will engage with HMRC at an early stage to address any areas of uncertainty and seek to resolve disputed matters in a timely manner.
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