UK tax strategy

1. UK Tax Strategy

The UK Tax Strategy outlined below applies to NFP UK Holdings Limited and all of its relevant subsidiaries, for the financial year 2024.

1.1. Strong governance

Directors (GFD). Day to day responsibility sits with the Group Financial Controller (GFC), who reports to the GFD.

The GFD and GFC seek to ensure that our tax strategy is consistent with the Group’s overall strategy and approach to risk. The GFD and GFC regularly discuss tax matters with the NFP Corp (US parent) tax department and NFP UK Holdings holds regular board meetings (including US parent representation).

As part of its risk management framework, NFP has a UK-based Compliance function. This function is led by a Group Compliance Director who is responsible for all compliance and internal governance and controls.

For advice on specific UK tax matters or strategic changes, NFP will engage with third party specialists for tax guidance.

1.2. Proactive management of tax risk

Tax risk is managed under group-wide governance and risk management frameworks and NFP actively manages its tax risks with the aim of minimising any adverse reputational or financial impact. NFP implements appropriate tax risk management measures that support the business and reflect commercial and economic activity, and regularly monitors their effectiveness.

The NFP Group periodically receives reports on the UK Group’s tax position from the GFC and provides additional governance and oversight of tax risks.

A key element of NFP’s tax risk management is having appropriately qualified and experienced people in tax-related roles, with specific tax responsibilities and accountabilities included in their job descriptions. Where there is significant uncertainty or complexity in relation to a tax risk, external advice is sought.

1.3. Responsible attitude towards arranging our tax affairs

NFP aims to comply with all tax filing, tax reporting and tax payment obligations.

NFP will at times use available UK incentives and reliefs to reduce UK tax costs, but only to the extent that they support genuine commercial objectives and are aligned to NFP’s understanding of the intent of the legislation.

The UK tax impacts of complex transactions are usually discussed up front with HMRC in order to enhance NFP’s tax risk management by taking proper account of HMRC’s interpretation of the legislation.

1.4. Constructive approach in dealings with HMRC

NFP strives to have a professional, collaborative relationship with HMRC which is based on the principles of transparency and justified trust.

The NFP Finance Department will proactively discuss areas of uncertainty or complexity in real time whenever possible to enable early agreement on such matters and to achieve certainty for both NFP and HMRC.

If errors are identified, we commit to disclosing these promptly and professionally and to have an open discussion with HMRC on the cause of the error and the necessary remediation.

This Tax Strategy document has been presented to and approved by the UK board, to ensure the Group is aligned in ensuring its tax affairs are managed in a consistent, honest, compliant and timely manner.