Gamma Communications plc and subsidiaries (“Gamma”) UK Tax Strategy
1. Gamma’s Tax Strategy
This tax strategy covers all the Gamma companies and explains the group’s approach to tax. Its publication follows the requirements set out in UK Finance Act 2016 Schedule 19 and adds to them where appropriate. It applies to the financial year ending December 2023 onwards and was approved by the Board on 27th July 2023.
Gamma’s Tax Risk Management
The Gamma CFO is responsible for the delivery of the tax strategy and for managing the tax risks that arise in the countries where Gamma operates. In managing these risks, Gamma’s approach is driven by the following three principles:
- To act with integrity and transparency in our dealings with all relevant stakeholders, including the tax authorities in the countries we operate
- To meet the tax compliance requirements required of us by filing returns and paying our tax liabilities on time
- To reduce the cost of doing business by utilising appropriate reliefs where it is legal and feasible to do so
The CFO relies on both the Head of Tax and the Finance Directors of each Business Unit and their finance teams to follow these principles and to make sure the Group’s tax affairs are aligned with wider corporate governance and risk management processes. Tax processes are regularly reviewed and refined, and Gamma carries out annual SAO reporting to HMRC.
3. Gamma’s attitude to tax planning
The Group is committed to acting with integrity and transparency. The financial professionals who deal with tax planning and compliance are expected to adopt this approach in all tax matters and to maintain the high ethical standards demanded by the professional bodies to which they belong. The relevant finance professionals involved in tax matters hold appropriate accounting qualifications and experience and undertake regular CPD to maintain and expand on their knowledge.
Gamma’s attitude to tax planning is:
- not to enter into transactions where the main purpose is to gain a tax advantage; and,
- not to make interpretations of tax law that are opposed to its original spirit.
Gamma seeks to structure its affairs in a tax efficient manner where there is a commercial benefit to do so, however, the Group will not use tax havens, take an aggressive interpretation of tax legislation or use artificial tax avoidance schemes.
To support us in ensuring that we have interpreted tax law and its spirit correctly, we seek advice from accounting firms, legal firms and tax counsel who have experience of working with large international groups. For example, we may consult on matters such as transfer pricing cross border to ensure pricing is at an arm’s length basis to ensure that Gamma pays an appropriate amount of tax within the jurisdictions in which we operate, based on the economic substance of the transaction
In summary, we will only engage in tax planning when it is aligned to our commercial and economic activity and does not lead to an abusive result.
4. Gamma’s tolerance to tax risk
Gamma’s level of acceptable tax risk is considered at least annually by the CFO, Board and appropriate sub committees. They will take the needs and interests of stakeholders into account when considering the level of risk while ensuring Gamma acts with integrity and transparency.
Individuals are not given delegated responsibility which would allow them to set their own level of risk which could be taken in tax planning. The Gamma finance team regularly communicate with one another on matters which may impact tax and any member of the team who is involved in tax planning has been instructed not to adopt a tax position without consultation; every member of the team has full access to the CFO. The Head of Group Tax oversees tax compliance activities on a day-to-day basis and reports to senior management.
The CFO will keep the Board up to date on tax matters and will take specific matters to the Board for consideration on an exceptional basis particularly if there are doubts over how to apply the tax strategy to a specific set of circumstances.
5. How Gamma works with tax authorities
An important part of Gamma’s tax strategy is the maintenance and development of a strong, proactive working relationship with HMRC and the other tax authorities where we operate. This is achieved in part by making sure our compliance obligations are met, for example that tax returns are complete and correct and that tax payments are made on time. Gamma also seeks to be transparent with tax authorities and where there is uncertainty as to the intended tax consequences of either new business practices or new legislation, we will seek to work with tax authorities on a real time basis to understand our obligations and make sure the right amount of tax is paid.