This strategy applies to Rioned UK Limited and its fellow UK group company Andy Guest Jetters Limited (the UK Group). Both are members of the Heico Holdings group (the Group).
It is published in accordance with Schedule 19 of the Finance Act 2016 (the Schedule), as part of the duty imposed on Rioned UK Limited, as the representative UK Company, to prepare and publish a UK Sub-Group Tax Strategy under paragraph 19(2) of the Schedule in the current financial year ending 31 December 2018 and has been made available to be freely accessed by the public online.
The content of this document is relevant as at the date of publication and will be updated when necessary.
References to ‘UK Taxation’ are to the taxes and duties set out in paragraph 15(1) of the Schedule which include Income Tax, Corporation Tax, PAYE, NIC, VAT, Insurance Premium Tax, and Stamp Duty Land Tax, Stamp Duty and Customs & Excise Duties. References to ‘tax’, ‘taxes’ or ‘taxation’ are to UK taxation and to all corresponding worldwide taxes and similar duties in respect of which the Group has legal responsibilities.
The UK Group: Approach to tax
Approach to tax risk management and governance
The approach of the Group in the UK to tax risk management and governance is to meet three key principles:
- Compliance with all statutory arrangements
The UK Group respects the law in the UK. This means that it complies with its legal obligations for tax, that it aims to file its tax returns on time with full and adequate disclosure of all relevant matters, and that it assesses and pays its taxes on time.
The UK Group does not take an aggressive approach to tax planning or compliance. This means that it will only undertake transactions that it is prepared to fully disclose and that it only undertakes transactions that have a strong underlying commercial motivation, and that are not artificial or contrived.
The UK Group conducts intragroup transactions on an arm’s length basis and complies with its obligations under transfer pricing rules in the UK.
- Strong and robust governance at every level
The CEO/Managing Director, Jan Pieters, has responsibility for and implements the UK Group’s Approach to Tax in the UK. They are also responsible for ensuring that policies and procedures that support the Group’s approach are in place, maintained and used consistently, and that the finance team has the skills and experience to implement the approach appropriately.
- Minimising exposure to tax risk
As part of its risk management system, the UK Group identifies, assesses and manages tax risks and accounts for them appropriately. It implements risk management measures including controls over compliance processes and monitors their effectiveness, with the aim of continual improvement.
Approach towards tax planning
- Operational driven approach:
As stated above, the Group’s aim is to achieve its commercial and industrial objectives so as to make profits on behalf of its stakeholders. It therefore only establishes itself in a country such as the UK (whether through a one-time project or recurring business) if this is necessary to bring the best quality of service possible to the customers in the country considered, and thereby achieve their commercial and industrial objectives.
The UK Group is established in the UK and does not have any operations in any other jurisdictions. The company does not use different jurisdictions to gain a tax advantage or otherwise engage in artificial tax arrangements.
The UK Group adheres to relevant tax law and seeks to minimise the risk of uncertainty or disputes with local tax authorities. To that end, as part of its risk management process, it seeks appropriate external tax advice to determine the appropriate application of rules.
Where tax incentives and/or exemptions are implemented by the UK and other governments in order to support investment, employment and economic development, the UK Group seeks to understand their impact and, if appropriate, applies them in the manner intended.
As an entity, the UK Group is suitable for carrying on its business activities in the UK and for complying with the prevailing regulatory environment.
- Global transparency:
The UK Group’s management recognise that there is a demand from public opinion in the UK and elsewhere for greater tax transparency. They aim to address this through clear and informative tax disclosures in line with OECD (Base Erosion Profit Shifting, action 13) and EU (Shareholders’ Rights Directive) proposals. The ultimate parent company reports information relating to income taxes in its Country by Country filing Statement.
- Responsibility to pay tax where profits arise:
The UK Group’s business operations take place wholly within physical locations within the UK, and therefore the company pays taxes in the UK where its profits are earned.
Level of tax risk that the UK Group is prepared to accept
In accordance with the Group’s Code of Ethics, the degree of tax risk allowed is minimal. The Group does not engage in operations likely to bear an identified tax risk, whatever the economic benefit at stake. The UK Group abides by these Group policies. To that end, its finance team proactively evaluates, manages and monitors potential risks to ensure they are properly mitigated. Where a significant uncertainty or complexity arises, they seek external advice and liaise with HM Revenue & Customs (HMRC) where appropriate.
From time to time the UK Group’s tax positions may be challenged by HMRC, (potentially due to divergence of interpretation). In such a case, the finance team, together with their professional advisers, ensure that the company’s interest is protected in accordance with the relevant legislation, published guidance and external advice.
Over and above its compliance with UK tax law neither the Group nor the UK Group undertakes activities the tax implications of which might lead to reputational damage in the areas of business, investment and public opinion.
The approach of the UK Group to dealings with HMRC
The UK Group seeks to build and sustain a constructive relationship with HMRC, based on mutual respect. It works collaboratively wherever possible with HMRC to resolve disputes and to achieve early dialogue and agreement for certainty purposes. It does its best to respond appropriately and on time to HMRC requests for information regarding transactions or business processes.
DATE OF PUBLICATION – 31 December 2018 relating to Financial Year 31 December 2018