United Trust Bank Limited (“UTB”) is a UK based specialist bank. It operates solely in the UK, raising capital and deposits and lending these funds to a range of borrowers. It is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority.
This tax strategy applies to UTB and to the group of companies headed by UTB Partners Plc, UTB’s parent, in accordance with paragraph 16(2) of Schedule 19 to the Finance Act (FA) 2016. In this strategy, references to ‘the UTB Group’ or ‘the Group’ are to the group of companies headed by UTB Partners Plc. This tax strategy was published on 9th October 2023 and the Group regards this publication as complying with its duty under paragraph 16(2) of Schedule 19 to the FA 2016 in its financial year ended 31 December 2023.
This strategy applies from the date of publication until it is superseded.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 to the FA 2016 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 in respect of which the Group has legal responsibilities.
The UTB Group 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 its wider corporate reputation in line with the Group’s overall high standards of governance.
3. Governance in relation to UK taxation
- Ultimate responsibility for UTB Group’s tax strategy and compliance rests with the Board of UTB;
- Executive management of the Group’s tax affairs is delegated by UTB’s Board to the Chief Financial Officer (‘CFO’), who is the Bank’s Senior Accounting Officer (‘SAO’);
- The Audit Committee monitors the integrity of the Group’s financial reporting system, internal controls and risk management framework, including those elements relating to taxation;
- The Chief Executive Officer (‘CEO’) and CFO are qualified Chartered Accountants with a clear understanding of the importance of good tax governance;
- Day-to-day management of the Group’s tax affairs is delegated to the finance team which reports to the CFO;
- The finance team comprises appropriately qualified individuals;
- Advice is sought from suitably qualified and experienced external advisers where appropriate;
- The Board ensures that the Group’s tax strategy is one of the factors considered in all significant business decisions;
- The CFO reports to the Audit Committee and the Board on the Group’s tax affairs and risks during the year, also updating them for any significant tax matters arising (if any) within the Group.
4. Risk Management
- The UTB Group 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 systems;
- The Group 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 the finance team who manage or process matters which have tax implications;
- Advice is sought from suitably qualified and experienced external advisers where appropriate.
5. Attitude towards tax planning and level of risk
The UTB Group 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, the Group seeks to apply available tax incentives, reliefs and exemptions in line with, and in the spirit of, tax legislation. The Group does not undertake tax planning unrelated to such commercial transactions.
The level of risk which the Group accepts in relation to UK taxation is consistent with its overall objective of achieving certainty in its tax affairs. At all times the Group 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 Board 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.
The Group has adopted the Code of Practice on Taxation for Banks.
6. Relationship with HMRC
The UTB Group seeks to have a transparent and constructive relationship with HMRC.
The Group ensures that HMRC is kept aware of any 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, the Group 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.