Attitude towards tax planning as far as it affects UK taxation
The Willis Towers Watson Code of Conduct requires all colleagues to always operate with honesty, integrity and fairness in everything that they do.
The UK group will engage in tax planning to ensure that it pays the right amount of tax, and mitigates excess tax liabilities within the parameters of UK law, in line with the Group’s responsibilities to its shareholders and other stakeholders.
To the extent that the UK group looks to undertake tax planning it will not create, encourage, promote or use arrangements or structures that
- set out to achieve results that are contrary to the clear intention of Parliament in enacting relevant legislation;
- rely for their effectiveness on HMRC having less than the relevant facts; or
- are highly artificial or highly contrived and seek to exploit shortcomings within the relevant legislation
Where we are concerned that any action may potentially breach the above, we will commission external professional advisers to provide guidance and the relevant technical analysis to enable us to conclude on whether an action is acceptable tax planning.
We may also seek external tax advice on the impact of new legislation or changes to legislation, both domestic and international, that may impact our UK business.
Approach of the group towards its dealings with HMRC
The UK Group operates under the Real Time Working initiative, with regular dialogue with its Customer Relationship Manager (CRM) and relevant specialists within HMRC. The UK Group notifies HMRC on a real-time basis of material transactions, and responds to all requests for information from HMRC and files all returns in a timely and open manner
Where there is uncertainty in the application of UK law, the UK Group will consider engagement with HMRC to try and agree a mutually acceptable position, under the Real Time Working initiative as set out above.
To the extent that the UK group and HMRC are unable to reach agreement on the interpretation of legislation then the UK Group will consider referral of the issue to the UK Tax Tribunal, or if more appropriate the use of alternate dispute resolution.
Approach to risk management and governance in relation to UK taxation
The UK group includes a dedicated Tax team made up of professionally qualified and experienced employees. This team is part of the wider global tax team that is led by the Global Tax Director who directly reports to the Chief Finance Officer. Regular updates are made by the Global Tax Director to the Group Audit Committee. Given the material nature of the UK to the group the management of UK tax risk is a principle aspect of the Global Tax Director’s role and any material risks will be communicated to the Group Audit Committee.
The Heads of the various Finance groups in the UK are in regular dialogue with both the business and the Tax Team. This dialogue ensures that issues that have a material tax impact are addressed and items that create tax risk are effectively managed.
The Boards of Directors of the various UK companies in the UK group will consider any tax risks in the transactions that they are asked to approve. The Directors of the UK companies have identified the Senior Accounting Officers (SAOs) for their company and reviewed the processes that the SAOs have in place to ensure that its tax affairs are materially correct.
Level of risk that the group is prepared to accept in relation to UK taxation
The UK Group does not accept risk in relation to UK taxation that is outside the normal commercial levels of risk that arise from the risk of inadvertent error or a difference in interpretation of legislation.
We consider that the above statement complies with our obligation under para 16(2) of Sch 19 Finance Act 2016.