Stannah Lifts Holdings Limited and subsidiary companies
Policy on Tax risk management and strategy
High Level Overview
The Stannah Group is a multinational business with subsidiaries and branches in a number of countries.
The Group has strategic tax objectives focused in the following areas
- Compliance – for tax jurisdictions where an obligation arises on a Group organisation; to submit all appropriate tax returns and pay amounts of tax due within the statutory deadlines.
- Tax risk management – to prevent disputes with Revenue authorities, wherever they may potentially arise. To only take a position in our computations where it would be more likely than not, that the Revenue would accept this as being an appropriate interpretation of the tax law.
- Avoidance of the facilitation of tax avoidance by Group employees, its customers, suppliers and others commercially connected with Group businesses.
- Commercial objectivity – we will structure transactions to suit their commercial rationale. Where there is a choice on how to structure the transaction, we will consider the tax impact but we will not enter into a transaction solely for a tax benefit.
The Board of Directors (“BoD”) of the Company acknowledges its obligation for fully complying with all relevant tax laws effective for the jurisdictions in which Group organisations operate. Approval of tax strategy is, ultimately owned by the BoD but effectively delegated to the Group Financial Director (“GFD”).
The BoD also recognise the obligations placed on it by UK Law in respect of the Criminal Finances Act 2017. The management of Tax compliance shall therefore also include the management of the risk of the facilitation of evasion of tax in any form.
The GFD shall ensure a suitably competent resource is available to meet the objective of the BoD in each jurisdiction in which a Group organisation has a tax obligation. The GFD shall delegate compliance responsibilities to that suitably qualified resource for the purposes of delivering accurate Tax Returns on behalf of Group organisations.
The framework below underpins how the strategic tax objectives will be delivered:
- The Group Tax Department (“GTD”) shall understand the compliance obligations in each jurisdiction, and know how those obligations are to be fulfilled.
- For each Tax Return dealt with directly by GTD there will be in place a robust review process. For Returns dealt with by third party advisors GTD will assess whether the abilities and competences of the advisors appointed may reasonably be expected to be of a standard necessary to meet Group compliance needs in the jurisdiction concerned.
- Competent external advisors shall be used to confirm or advise upon technical positions and legal understandings when required.
- All material positions taken in the Tax Returns shall be made explicit to the person approving the Return and be supported by comprehensive documentation, and disclosure in the Return when appropriate.
Tax risk management
- Group accounting policies shall take account of applicable tax law in their construction and execution.
- GTD shall maintain a current awareness of applicable tax law and the progressive development of that law inasmuch as it does or may in the future apply to Group operations. Training of Tax staff shall be directed towards achieving this.
- Employees involved with transactions that have relevance for accurate completion of Tax Returns shall be trained to be aware of the reporting requirements and obligations related to those transactions.
- GTD will provide a robust audit process to ensure the accuracy and consistency of the Returns with which it deals. Wherever and whenever practicable it will review and question Returns that have been constructed by the staff or advisors of organisations not resident in the UK.
- Group companies shall ensure GTD is involved in any new or developing business activities or ventures to enabling all tax compliance and reporting consequences to be considered and understood, with appropriate provision made for reporting data for Tax Returns.
- All issues and uncertainties outside of the competences of GTD shall be referred to suitably qualified third party advisors.
- Group companies (and their advisors) shall foster good relationships with their Revenue authority and undertake all such dealings with said authority in a professional, courteous and timely manner.
- Advice sought and or obtained from third party advisors shall be relevant only to the commercial rationale of the Stannah operation concerned in respect of the jurisdiction in which it operates. A Stannah operation’s relationship with other Group organisations outside its operational jurisdiction will be considered only inasmuch as it is necessary to ensure the OECD arms length principle is maintained, such as for setting transfer prices.
- It is not the objective of the BoD to minimise the level of tax paid by Group organisations below that, which the law of the jurisdiction in which it operates, reasonably allows for.
Review and Application
This document is periodically reviewed for its relevance to the current financial year by the GTD with any amendments considered and approved by the BoD through the GFD. This policy has been reviewed and approved effective for the Financial Year ended 31 December 2020.