Tax Strategy

This document sets out the tax strategy for the 菜肱郭創利 (and its subsidiary companies).

The document is effective for the year ended 31 July 2024. The document will be reviewed annually
by the Finance Department and any amendments approved by the University Executive Board where
appropriate.

In accordance with guidance issued by HMRC on 31 March 2016, the document below sets out the
University’s:

A) Tax policy being applied
B) Approach to tax risk management and governance arrangements in relation to UK and
international taxation
C) Attitude towards tax planning (so far as it affects UK taxation)
D) Level of risk in relation to UK taxation that it is prepared to accept
E) Approach towards its dealings with HMRC

A) TAX POLICY

The University is committed to conduct its tax affairs in line with the best ethical practice and
professional standards and as such:

• Recognises its obligation to pay the correct amount of tax due in any territory.
• Will only enter transactions which have a commercial rationale and would be fully justifiable
to the public
• Will manage commercial and reputational risk by application of the tax risk strategy
• Will apply professional care and judgement to arrive at well-reasoned conclusions
• Will seek appropriate professional advice where tax law is complex, uncertain or subject to
interpretation
• Develop and foster good working relationships with tax authorities and work with similar UK
institutions to itself particularly through BUFDG, to shape future tax legislation where
appropriate and share best practice
• Will be open and transparent in all dealings with tax authorities and other relevant agencies
• Promote awareness of need for tax compliance across the University
• Will utilise legitimate incentives and tax reliefs to minimise tax costs of conducting its
activities, recognising that as a Charity, it also has responsibilities to protect its income to be
used for its Charitable purposes
• Will NOT enter into transactions that have a main purpose of gaining a tax advantage or
intentionally make interpretations of tax law that are opposed to the original spirit of the tax
legislation

B) RISK MANAGEMENT AND GOVERNANCE

The University recognises that its size and the diverse activities it carries out to achieve its
Charitable activities can make the application of tax legislation complex in some areas, but
that as a Charity, in other areas it can benefit from specific legislative tax benefits and reliefs
which can significantly reduce or eliminate tax risk. As such, the University has undertaken
regular reviews over the years to identify those areas of tax complexity and risk, and
endeavoured to introduce systematic controls and training to ensure appropriate
compliance with tax legislation is met.

The overall tax governance framework is set by the Executive Board and has delegated
responsibility for the implementation of that Policy to the Director of Finance and
appropriate members of the Director of Finance team. Within the Finance Team is a Tax
Team consisting of 3 appropriately experienced and tax qualified members who monitor the
day-to-day compliance of the University with tax matters, and ensure that procedures are
implemented to deal with changes in tax legislation or internal system changes, to maintain
continued compliance.

The Finance Team report to the Deputy Director of Finance and through the Director of
Finance , to the University Executive Board on an as needs basis, identifying key new tax
legislation where risks, additional resource needs or systems changes may be required, and
advising on the tax procedures which should be followed for large and unusual transactions
that the University may be undertaking, to ensure that compliance with the Tax Policy is
maintained.

The University’s accounting system has been designed to put in tax controls and compliance
checks wherever possible and the Tax Team is in place to review unusual and significant
transactions, prepare and file all appropriate tax returns, monitor tax compliance on an on-
going basis and provide an easy to access help-line and training for the wider University staff
base. A comprehensive dialogue takes place between the Tax Team, Finance Department,
Director of Finance and Executive Board through regular meetings to identify key business
transactions and professional tax advice is sought in areas of doubt or significance. Any
potential significant tax risks which are identified are reported regularly to the Director of
Finance and through the risk management process if necessary. The combination of all these
procedures means that tax risk is minimised to the lowest feasible level.

C) ATTITUDE TO TAX PLANNING

As noted in the Tax Policy at (A) above, the University recognises that, as a Public Body, it
has a duty to be compliant with all appropriate aspects of UK and international tax
legislation and to pay the correct amount of tax due accordingly. However, it also has a
responsibility to arrange its finances in compliance with the law of any relevant territory, to
maximise the amount of funds available to it and to conduct its charitable purposes of
education and research for the public good.

The University’s over-riding Policy, with regard to tax planning, is that it will not enter into
transactions that have a main purpose of gaining a tax advantage or intentionally make
interpretations of tax law that are opposed to the original spirit of the tax legislation.
Therefore, the University will only undertake to arrange the transactions it is carrying out
for its charitable purposes, to minimise tax costs in a way which is considered to be
compliant with appropriate tax legislation at that time. It does however recognise that, due
to complexities of tax legislation and commercial facts and circumstances, there will from
time to time be alternative views or approaches where the tax costs will be different and in
these situations, it will use its best judgement in the decision making process. Professional
advice would be obtained in these circumstances, to make sure that all aspects of UK tax
legislation have been adequately considered.

D) LEVEL OF ACCEPTABLE TAX RISK

The University has structured its accounting systems, finance department and
communication processes in a way to minimise tax risk to the lowest level possible, but
recognising the need to balance the degree of complexity of the tax legislation applicable to
its activities with the cost of having to administer those controls and the amount of tax at
stake.

E) RELATIONSHIP WITH HM REVENUE AND CUSTOMS (HMRC)

The University is committed to being open and transparent in its dealing with HMRC. To this
end, the University:
• Will conduct its dealings with HMRC in a courteous, collaborative and timely manner
• Make fair, accurate and timely disclosure in correspondence and returns, and
respond to queries and information request in a timely manner
• Seek to resolve issues with HMRC as soon as possible
• Aim to minimise risk of future challenge by HMRC and bring certainty to our tax
affairs by promptly entering into discussions with HMRC, where allowed by
legislation, on complex matters where the tax treatment is uncertain.