Integrity and good conduct are central to our culture and approach to risk management. We aim to comply with both the spirit and letter of the law in tax matters.
This tax strategy applies to all Schroders Group companies, Schroders managed funds and to our dealings with our clients.
- Responsibility for the tax strategy, the supporting governance framework and management of tax risk ultimately sits with the Chief Financial Officer (CFO). Day-to-day responsibility for each of these areas sits with the Group Head of Tax, who reports to the CFO.
- The Group's tax strategy is reviewed by the Board Audit and Risk Committee annually. It is supported by a tax governance framework, which aligns to the Group's wider risk and control framework. Independent monitoring and reporting of tax risks and controls is supported by Group Risk and key risks and issues related to tax are escalated to and considered by the Group Risk Committee and the Board Audit and Risk Committee on at least an annual basis.
Management of tax risk
- As a large multi-national organisation, with operations in 38 countries, the Group is exposed to a variety of tax risks. These can be grouped under the following headings:
- Tax compliance and reporting risks, which cover risks associated with compliance failures such as submission of late or inaccurate returns, the failure to submit claims and elections on time or where finance or operational systems and processes are not sufficiently robust to support tax compliance and reporting requirements.
- Transactional risks, which arise where transactions are carried out or actions are taken without appropriate consideration of the potential tax consequences or where advice taken is not correctly implemented.
- Reputational risk looks beyond financial risks to the wider impact tax risk may have on our relationships with our stakeholders, including shareholders, clients, tax authorities and the general public.
- We look to manage tax risk in a similar way to any area of operational risk across the Group. The Group Tax function is generally responsible for identifying, managing and monitoring tax risks relating to the Group and its subsidiaries. Business heads, supported by Group Tax, are similarly responsible for identifying, managing and monitoring the tax risks relating to our various businesses. Line management is then supplemented by oversight functions, including Group Risk and Group Internal Audit.
- Group Tax is made up of a team of tax professionals based predominantly in London. In addition to their oversight role, they provide advice to the business and its managed funds on tax-related issues, undertake or assist with tax filings, manage relationships with tax authorities and assist with various forms of tax and financial reporting. Internal controls and escalation procedures are put in place with the aim of identifying, quantifying and managing key risks.
- Where appropriate, we look to engage proactively with tax authorities to disclose and resolve issues, risks and uncertain tax positions. The subjective nature of many tax rules does however mean that it is often impossible to mitigate all known tax risks. Indeed, in certain situations, an element of tax risk may be maintained, where we believe our approach is consistent with the principles set out in our tax strategy and where the range of potential outcomes is in accordance with the Group's risk appetite. As a result, at any given time, the Group and its managed funds may be exposed to financial and reputational risks arising from their tax affairs.
Tax compliance and relationship with tax authorities
- We look to comply with all of our tax filing, tax reporting and tax payment obligations globally.
- We act with honesty and integrity in our dealings with the tax authorities. We also look to maintain open and transparent relationships with the tax authorities in the key jurisdictions in which we operate. This may take the form of discussing key developments in our business and the potential impacts of those developments. Equally, it may involve disclosing and seeking to resolve a known issue prior to the filing of the relevant tax return.
- From time to time, our views on the appropriate tax treatment in any given case may differ from those of the tax authorities. Where such circumstances arise, we will work constructively and proactively with the tax authorities in question with a view to achieving an early resolution to any matters arising.
- We comply with the requirements of HM Revenue & Customs (HMRC)'s Code of Practice on Taxation for Banks. Under the Senior Accounting Officer regime in the UK, we also provide an annual certification to HMRC confirming that we have appropriate accounting arrangements to allow our tax liabilities to be calculated correctly.
- Schroders recognises that it has a responsibility to pay an appropriate amount of tax in each of the jurisdictions in which it operates. We aim to balance this with our responsibility to our shareholders and clients to structure our affairs and their affairs in an efficient manner. Accordingly, we may utilise tax incentives or opportunities for obtaining tax efficiencies where these:
- are not considered to carry significant reputational risk,
- are aligned with the intended policy objectives, and
- are aligned with our business or operational objectives.
- External advice may be sought in relation to tax planning or areas of complexity or uncertainty to support the Group in complying with its tax strategy.
- We apply a consistent global approach to allocating costs and revenues that fairly recognises the economic contribution of each of our businesses.
- Remuneration packages for employees and directors are structured so that the Group reasonably believes that the proper amounts of tax and social security contributions are paid on the rewards of employment.
- We will not promote or work with other advisers to support tax planning for our clients unless those arrangements are consistent with our tax strategy.
- We will contribute to the development of UK and international tax policy and legislation where appropriate. As part of this process, we participate in the tax committees of various industry groups and professional associations.
- We are supportive of initiatives to improve international transparency on taxation matters, including OECD measures on country-by-country reporting and automatic exchange of information.
- We will continue to demonstrate our commitment to transparency by publicly disclosing all the taxes that the Group bears or collects and the regions in which these taxes are borne or collected.
- We do not tolerate tax evasion, nor do we tolerate the facilitation of tax evasion by any person(s) acting on the Group's behalf.
Schroders plc regards the publication of this tax strategy as complying with the duty under paragraph 16(2) of Schedule 19 of the Finance Act 2016 to publish the group tax strategy in the current financial year.