This Tax Strategy applies to nmcn plc and to the group of companies headed by nmcn plc in accordance with paragraph 16 of Schedule 19 to the Finance Act 2016. A list of the entities to which it applies is set out in Appendix I. In this Tax Strategy, references to ‘nmcn plc’, or ‘the Group’ are to all entities within Appendix I. The Tax Strategy is being published in accordance with paragraph 16(4) of the Schedule.
This Tax Strategy applies from the date of publication until it is superseded. References to ‘UK Taxation’ are to the taxes and duties set out in paragraph 15(1) of the Schedule which include Income Tax, Corporation Tax, PAYE, NIC, VAT, Insurance Premium Tax, and Stamp Duty Land Tax. References to ‘tax’, ‘taxes’ or ‘taxation’ are to UK taxation and to all corresponding worldwide taxes and similar duties in respect of which the Group has legal responsibilities.
nmcn plc is committed to full compliance with all statutory obligations and full disclosure to relevant tax authorities. The Group’s tax affairs are managed in a way which takes into account the Group’s wider corporate reputation in line with nmcn plc’s overall high standards of governance.
Ultimate responsibility for nmcn plc’s tax strategy and compliance rests with the Board of nmcn plc. Executive management of tax matters, including the Group’s tax strategy and compliance, is delegated by the Board to the Group Finance Director.
The Audit Committee’s requirement to monitor the integrity of nmcn plc’s financial reporting system, internal controls and risk management framework, expressly includes those elements relating to taxation.
Day-to-day management of nmcn plc’s tax affairs is delegated to the Financial Controller, who reports to the Group Finance Director during the year. The Finance and Human Resources teams are staffed with appropriately qualified individuals.
The Board ensures that nmcn plc’s tax strategy is one of the factors considered in all investments and significant business decisions taken.
nmcn plc operates a system of tax risk assessment and controls as a component of the overall internal control framework applicable to the Group’s financial reporting system.
nmcn plc seeks to reduce the level of tax risk arising from its operations as far as is reasonably practicable by ensuring that reasonable care is applied in relation to all processes which could materially affect its compliance with its tax obligations.
Processes relating to different taxes are allocated to appropriate process owners, who carry out a review of activities and processes to identify key risks and mitigating controls in place. These key risks are monitored for business and legislative changes which may impact them and changes to processes or controls are made when required.
Appropriate training is carried out for staff outside of the Finance or Human Resources teams who manage or process matters which have tax implications.
Advice is sought from external advisers where appropriate.
nmcn plc 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, nmcn plc seeks to take advantage of available tax incentives, reliefs and exemptions in line with, and in the spirit of, tax legislation. nmcn plc does not undertake tax planning unrelated to such commercial transactions.
The level of risk which nmcn plc accepts in relation to UK taxation is consistent with its overall objective of achieving certainty in the Group’s tax affairs. At all times nmcn plc 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 Group Finance Director 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.
nmcn plc seeks to have a transparent and constructive relationship with HMRC through regular meetings and communication in respect of developments in nmcn plc’s business, current, future and retrospective tax risks, and interpretation of the law in relation to all relevant taxes.
nmcn plc 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, nmcn plc 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.
ADOPTED BY THE BOARD ON 13 DECEMBER 2017
List of entities covered by this Tax Strategy