Canary Wharf Group Residential Limited Group of Companies – Tax strategy
This document outlines the tax strategy of the UK incorporated subsidiaries of Canary Wharf Group Residential Limited (“Canary Wharf Residential”) and sets out its approach to tax and the management of its relationship with HM Revenue & Customs (“HMRC”). It has been prepared by Canary Wharf Residential’s in-house tax department and is aligned to the tax strategy of Canary Wharf Group Investment Holdings Ltd (“CWGIH”) and has been reviewed and approved by Canary Wharf Residential’s Board of Directors.
Canary Wharf Residential seeks to comply fully with its tax reporting obligations in the UK and in other jurisdictions and to provide support to its investors and stakeholders to help them comply with their reporting obligations.
Canary Wharf Residential’s in-house tax team are responsible for identifying and managing risk associated with tax across the group, and also ensuring that tax returns and payments of tax are submitted accurately and on time. This team is supported by external advisors where necessary.
It is Canary Wharf Residential’s policy to avoid engaging in any transaction or structure that is contrary to the spirit and purpose of tax legislation, or seeks to rely upon non-disclosure (in whole or in part) to HMRC. This includes where such a tax advantage may be exploited by a third party.
Approach to risk management and governance arrangements in relation to UK taxation
The effective assessment and management of risk (including tax risk) is key to the delivery of our strategy. The Board of Directors has the responsibility of establishing the group’s appetite for risk based on the balance of potential risks and returns in achieving its strategic objectives and has overall responsibility for identifying and managing risk. Risk management is embedded in our culture, and employee training.
The Chief Finance Officer (‘CFO’) is the Board member with executive responsibility for tax matters and our appointed Senior Accounting Officer. The CFO and Director of Tax report material tax issues and risks to the Board quarterly.
Day-to-day management of the Group’s tax affairs is the responsibility of the Director of Tax who reports directly to the CFO. The tax team is led by the Director of Tax, and to meet our commitments we seek to employ appropriately qualified professionals and ensure that appropriate training is provided for employees involved in the tax process.
Management of tax risk is achieved through:
- The audit committee of CWGIH whose key responsibilities include the monitoring and review of the effectiveness of our internal control and risk management framework and overall approach to monitoring areas of risk, including prevention of the facilitation of tax evasion;
- Working with business units to ensure that the Director of Tax is aware of strategies and transactions at an early stage so that the tax consequences and risks can be identified and managed;
- Monitoring changes in tax legislation and practice so that the effects can be taken into account;
- Maintaining systems and controls to ensure that tax returns are accurately prepared and submitted in accordance with statutory time limits;
- Ensuring that other finance functions are aware of and consider relevant tax issues;
- Reviewing financial statements of group companies to ensure that tax disclosures are in accordance with relevant statute and guidance and that all matters of tax significance are identified and treated appropriately;
- Obtaining advice from external consultants where necessary.
Our attitude towards tax planning
Responsible and commercial tax planning is undertaken where necessary so that transactions do not give rise to tax liabilities in excess of those required by law and double taxation does not arise.
Canary Wharf Residential will not enter into any tax planning arrangements that it considers to be abusive.
Canary Wharf Residential endeavours to comply with all relevant legislation and practice in relation to its tax affairs, paying taxes due that are commensurate with realised income, profits and gains and in accordance with the law and practice.
Canary Wharf Residential will seek appropriate tax advice from external advisors where:
- Transactions are complex; and/or
- The law applying to a particular transaction is uncertain; and/or
- The amounts at stake are substantial.
Clearances may be sought from HMRC where possible.
Our relationship with HMRC and level of risk
Canary Wharf Residential has a low tolerance for tax risk. We are committed to acting with integrity and transparency in all tax matters, and we have an open, up-front and no-surprises policy in dealings with HMRC. We are in regular discussions with our customer compliance manager at HMRC, HMRC are kept informed and are asked for pre-clearance where applicable in relation to complex areas and transactions.
In summary, Canary Wharf Residential looks to minimise the level of tax risk and at all times seeks to comply fully with its regulatory and other obligations and to act in a way which upholds its reputation as a responsible citizen.
This strategy published on 15 December 2022 applies to all UK incorporated subsidiaries of Canary Wharf Group Residential Limited and meets the requirements of paragraph 16(2) Schedule 19 to the Finance Act 2016 in respect of the accounting period ended 31 December 2022.