This tax strategy describes the Barbican Group’s (“Barbican’s”) approach to conducting its tax affairs and managing its tax risks. Publication of this strategy is in compliance with Barbican’s duty under Schedule 19 of the Finance Act 2016.
References to “tax” are to the taxes and duties set out in paragraph 15(1) of the Schedule which include inter alia: Income Tax; Corporation Tax; PAYE; NIC; VAT; Insurance Premium Tax; and Stamp Duty Land Tax.
Ultimate responsibility for the ownership of this strategy resides with the Barbican Group Holdings Limited Board (“the Group Board”). However day-to-day management is delegated to the Group Finance Director. The strategy shall be reviewed and updated annually for consideration and approval by the Group Board.
Attitude to tax planning and risk appetite
Barbican is committed to complying fully with all applicable tax laws, rules and regulations, without exception.
Barbican shall undertake all tax planning with a view to delivering long-term economic value to its shareholders.
Barbican shall not engage in aggressive tax planning transactions, and shall not enter into transactions which lack a commercial business purpose.
Where Barbican deems there is insufficient technical expertise within the group, external tax advice shall be sought.
Barbican does not prescribe a level of acceptable tax risk, and assesses each matter on its specific facts and circumstances, and within its governance framework.
Approach to risk management and governance arrangements
Barbican operates a system of tax risk assessment and controls as part of its overall internal control framework. Barbican seeks to reduce the level of tax risk arising from its operations as far as is practicable by ensuring that reasonable care is applied in relation to all processes which could materially affect compliance with its tax obligations.
The Group Board and the Group Audit Committee have oversight on tax matters and are briefed on key tax developments and tax impacts of commercial transactions where and when deemed necessary, by the Group Finance Director.
Advice shall be sought from external advisors where appropriate. This could include situations where there is significant uncertainty or complexity regarding the tax treatment of a transaction, specialist knowledge is required on particular tax issues or where the consequences of new tax legislation or developments are uncertain.
Barbican is committed to preventing persons associated with it from engaging in criminal facilitation of tax evasion and, where possible, has procedures in place to identify and mitigate the risk of facilitating such tax evasion.
Approach towards dealings with HMRC
Barbican is committed to complying with its statutory obligations and making full disclosures to HMRC, together with maintaining an open and constructive relationship with the tax authorities.
In dealing with HMRC in relation to its tax affairs, Barbican shall fully disclose any inadvertent errors in submissions made to HMRC as soon as reasonably practicable after they are identified, respond promptly and with full disclosure to any enquiries received from HMRC, and engage in a cooperative and professional manner in all dealings with HMRC.