We operate a robust culture which is encapsulated within our Code of Conduct. This culture is built on ethics, individual responsibility and integrity to do the right thing. These principles provide the strong bedrock for how we conduct our own affairs, including our tax affairs, as well as how we work with our clients.
Our corporate sustainability agenda has also helped frame our tax strategy. This agenda is founded on the following guiding principles:
Upholding professional standards
Being transparent and fair
Fostering a culture of collaboration, and
We are committed to being a responsible and compliant taxpayer in the countries where we operate and we do this through robust governance, and clearly defined processes and controls.
The responsibility for our tax affairs rests with our Chief Operating Officer (“COO”) who is a member of our Executive Board. Our Supervisory Board also provides governance over our UK tax affairs.
Our COO delegates the day to day management of our tax affairs, through the operation of our tax function, to our Designated Tax Partner (“DTP”). Our DTP is authorised to make decisions and sign filings and other documentation in relation to our tax affairs on behalf of all of the partners of the firm.
We maintain robust processes and controls which are designed to minimise the risk of errors arising which could impact the amount of tax that we pay. These processes and controls are regularly monitored, reviewed and tested and underpin the submission of returns for our firm, for our partners and, as an employer, for our staff.
We undertake any transactions, and maintain relationships with other non UK PwC member firm’s on an arm’s length basis.
Our guiding principles and codes of conduct govern how we manage our own tax affairs. These are supported by both underlying detailed governance and risk management frameworks.
When structuring our affairs we will only ever do so based on sound commercial purposes and we will never act in a way that we believe could be considered inconsistent with our understanding of the intention of Parliament or which could be contrary to any anti abuse legislation.
Our internal controls and reporting lines aim to ensure that any part of our business intending to undertake a transaction or activity, as respects our own tax affairs, which is outside the normal course of our business model must always seek approval from our DTP. This is a practice which drives our consistent approach to structuring our affairs.
We have developed a detailed framework of internal controls to provide a robust and comprehensive approach to managing risk in relation to the taxation of our own affairs. This framework is structured to deliver a level of governance and oversight which is consistent with the standards we adopt to our work when undertaking our broader client engagements.
This detailed framework is based on the six elements of internal controls and internal quality controls.
Leadership responsibilities for quality within the firm
Relevant ethical requirements
Acceptance and continuance of client relationships and specific engagements
The framework, along with our other financial and operational systems, are subject to a rolling independent review by our internal audit team with results reported to our COO and Executive Board.
Our robust and comprehensive approach to managing risk in relation to tax is underpinned by:
Our partners are also required to conduct their personal affairs in a way which is aligned with our Code of Conduct.
We engage openly and constructively with HM Revenue & Customs on matters relating to our tax affairs. We share information about our commercial developments or transactions, especially where there are complex tax treatments. Where necessary we will seek formal or informal clearance from HMRC on uncertain tax positions insofar as they relate to our tax affairs.
Tax can be very complex so we approach our obligations with an appropriate level of analysis and consideration. Where we cannot reach agreement with HMRC on the proper interpretation of law, and there is no other practical means of achieving agreement, we may test the matter in the Courts. We aim to collaborate appropriately with HMRC on the conduct of such actions.
Our tax strategy defines our approach to managing our own tax affairs. It, along with our underlying operational governance in relation to our tax affairs, has been approved by our Chief Operating Officer and is subject to periodic review by our Executive and Supervisory Boards.
This tax strategy is published by PricewaterhouseCoopers LLP and the group of UK companies primarily held through its wholly owned subsidiary, PwC Holdings (UK) Limited.
Our strategy is compliant with the requirements of para 16(2) and 25(1) of Schedule 19, Finance Act 2016 and relates to our 30 June 2020 year end.