Tax Strategy

Develop Training Group Limited (and subsidiary companies) Tax Strategy September 2017

Introduction

This document has been approved by the board of Directors of Develop Training Group and its subsidiary companies and sets out the approach to dealing with tax matters within the group.

The document will be made available to all Stakeholders who are seeking clarification on the tax strategy of Develop Training Group Limited and will be published on Develop's intranet. The document is effective from 30th September 2017 and will be reviewed quarterly by the Board and amended where appropriate.

This strategy applies to Develop Training Group Limited and to the group of companies headed by Develop Training Group Limited in accordance with paragraphs 19 and 25 of Schedule 19 to the Finance Act 2016. A list of the entities to which it applies is set out below. In this strategy, references to 'Develop', 'the firm' or 'the group' are to all these entities. The strategy has been published in accordance with paragraph 16(4) of the Schedule by being included on Develop Training Limited's website.

Governance in relation to UK taxation

Ultimate responsibility for Develop's tax strategy and compliance rests with the Board of Develop. The Group FD is responsible for ensuring that the tax strategy is:-

  1. Applied consistently across all Develop companies.
  2. Does not conflict with Develop Training's overall approach to risk management and corporate governance.

Tax Principles

Develop Training will conduct its affairs within the following broad principles:-

  1. Comply with all relevant tax laws and regulations in the geographies in which it operates.
  2. Adopt an open, collaborative relationship with the tax authorities with full disclosure.
  3. Minimise tax payments provided they are both within the spirit of the Revenue's intention and the letter of the law.
  4. Use tax professionals, when appropriate, to ensure that tax decisions are consistent with the above principles.

Risk Management

Professional care and judgement will be applied by the Group Finance Director and reported to the Board when addressing tax risk and ensuring rational conclusions on how the tax risks should be managed are reached.

Advice is sought from Develop's tax advisors where appropriate.

Attitude towards tax planning and level of risk

Develop manages risks to ensure compliance with legal requirements in a manner which ensures payment of the right amount of tax.

When entering into commercial transactions, Develop seeks to take advantage of available tax incentives, reliefs and exemptions in line with, and in the spirit of, tax legislation. Develop does not undertake tax planning unrelated to such commercial transactions.

The level of risk which Develop accepts in relation to taxation is consistent with its overall objective of achieving certainty in the firm's tax affairs. At all times Develop seeks to comply fully with its regulatory and other obligations and to act in a way which upholds its reputation as a responsible corporate citizen.

In relation to any specific issue or transaction, the Board is ultimately responsible for identifying the risks, including tax risks, which need to be addressed and for determining what actions should be taken to manage those risks, having regard to the materiality of the amounts and obligations in question.

Relationship with HMRC

Develop seeks to have a transparent and constructive relationship with HMRC through regular meetings and communication in respect of changes in Develop's business, current, future and retrospective tax risks, and interpretation of the law in relation to all relevant taxes.

Develop ensures that HMRC is kept aware of significant transactions and changes in the business and seeks to discuss any tax issues arising at an early stage. When submitting tax computations and returns to HMRC, Develop discloses all relevant facts and identifies any transactions or issues where it considers that there is potential for the tax treatment to be uncertain.

Any inadvertent errors in submissions made to HMRC are fully disclosed as soon as reasonably practicable after they are identified.


List of entities covered by this Tax Strategy:

  • Develop Training Group Limited
  • Develop Training Limited
  • Develop Solutions Limited
  • Develop Training Employee Benefit Limited