Howden Group Holdings Limited, and all its relevant subsidiaries, regard the publication of this tax strategy as complying with its duty under paragraph 16(2) of Schedule 19 of the Finance Act 2016 to publish the Group’s UK tax strategy.
The tax principles below relate to the Group’s financial year ended 30 September 2022.
Responsibility for the tax strategy, the supporting governance framework and management of tax risk ultimately sits with the Group Chief Financial Officer. Day-to-day responsibility for each of these areas sits with the Group Head of Tax.
The Group's tax strategy aligns to the Group's wider risk and control framework. Key risks and issues related to tax are escalated to and considered by the Group Audit Committee on a regular basis, and to the Board of Howden Group Holdings at the discretion of the Chair of the Group Audit Committee.
The Group also operates a number of internal working groups, which bring together the heads of the Legal, Finance, Treasury and Tax departments to ensure that commercial decisions are supported by timely and reliable tax advice.
Tax risk management
Howden Group is an international insurance intermediary operating across the globe and is exposed to a variety of tax risks that are managed actively with the aim of minimising any adverse reputational, regulatory or financial impact.
A key element of the Group's risk management framework is having suitably qualified and experienced people in tax roles, who are supported through training to ensure they keep up to date with changes to tax legislation. Where there is substantial uncertainty or complexity in relation to a tax risk, external advice is sought.
Throughout the year, the Group has continued to acquire other companies. Due diligence is completed on potential targets to ensure that tax risks are understood, and actions are taken to ensure compliance with the Group’s tax strategy.
Mitigation of risks
The Group aims to manage tax risk in a similar way to any area of operational risk across the Group. The Group activities are supported by oversight functions, including Group Tax, Group Risk and Group Internal Audit.
Where appropriate, the Group looks to engage with tax authorities to disclose and resolve issues, risks and uncertain tax positions.
Attitude of the Group to tax planning
The Group recognises it has a responsibility to pay the right amount of tax in each jurisdiction in which it operates and aims to do so while fulfilling its responsibility to its shareholders to structure its affairs in an efficient manner.
The Group acknowledges that there is a certain level of optionality in structuring business arrangements and seeks to file tax returns that would not be subject to challenge. However, this does not preclude seeking to benefit from available and appropriate tax reliefs and incentives.
Approach towards dealings with HMRC
The Group aims to have an open and collaborative working relationship with HMRC by being straightforward and transparent in our communications to ensure they have appropriate information to assess our tax affairs.