INTRODUCTION
Scope
This document sets out the Tax Strategy for Howard de Walden Estates Holdings Limited and its subsidiaries (which together form ‘the Group’) for the year ending 31 March 2024 in compliance with part 2, schedule 19, paragraph 16 of Finance Act 2016.
The Tax Strategy, for which the Board of Directors (‘the Board’) has ultimate responsibility, is prepared and updated by the Senior Accounting Officer in collaboration with the Finance Team. Day to day responsibility for implementation of the Tax Strategy is delegated to the Director of Finance who works with an established Finance Department to comply with tax legislation and manage tax risk through internal processes and procedures.
The Group and its activities
The Group actively manages a diversified portfolio of real estate, being the freehold owner of most buildings within a 95 acre area of Marylebone. The Group is beneficially owned by members of the Howard de Walden Family and its estate has been under the family’s control since 1879. The Group is committed to protecting heritage, enhancing its landholding and building value over the long term, aligning shareholder prosperity with the well-being of the community, the environment and its other key stakeholders.
TAX RISK MANAGEMENT AND GOVERNANCE
Effective risk management is essential for the Group to be successful and the Board ensures that the Group has appropriate processes and procedures in place to identify and manage both ongoing and new tax risks, which may arise.
Major tax risks are documented in the Group’s risk register, particularly if they are likely to have a significant impact. The risk register is reviewed regularly and is reported to the Audit Committee and the Board by the Chief Financial Officer, who is the Group’s Senior Accounting Officer.
Acquisitions, redevelopments and disposals are undertaken to support the Group’s strategic objectives and may have a significant tax impact. There is formal reporting to the Board by the Property Director on these matters which may also include input from the Finance Team.
The Group’s Senior Accounting Officer monitors the Group’s tax accounting arrangements throughout the year. Responsibility for the Group’s tax management is undertaken by the Group’s Director of Finance, a Chartered Accountant with extensive knowledge and experience of tax matters relating to property. The Director of Finance reports to the Senior Accounting Officer.
As a large business and employer with activities based solely in the UK, the Group is subject to UK taxes including corporate taxes, property taxes, employment taxes, local taxes such as Council Tax and indirect taxes such as VAT.
Day to day tax compliance is undertaken by designated staff within a well-established Finance Department. These members of staff have a wealth of experience and technical expertise on tax matters and keep up to date with legislative changes through training and continuing professional development. Returns associated with most day-to-day tax compliance are completed in house, with appropriate levels of internal review. Annual Corporation Tax returns are prepared and submitted to HMRC by professional advisers, following input from the Finance Department.
The Senior Accounting Officer and Director of Finance actively monitor changes to existing tax legislation and the introduction of new tax legislation. The Group is proactive in seeking assistance and clarification from professional advisers on all changes to tax legislation to ensure appropriate processes and procedures are in place to mitigate tax risk.
ATTITUDE TO TAX PLANNING
The Group’s tax strategy is compliance based and its objective is to account for and pay all taxes in an accurate and timely manner, utilising statutory tax reliefs and allowances where available. The Group does not engage in tax planning schemes and does not enter into arrangements which could be perceived as aggressive.
All transactions entered into by the Group are undertaken for commercial objectives. The tax implications and risks of any large transactions are considered by the Senior Accounting Officer and Director of Finance, taking external professional advice where needed. The Board is updated regularly on any tax matters affecting the business.
The Group has close working relationships with professional advisers covering all aspects of taxation and will seek advice on any matter where there is uncertainty regarding the tax outcome of a transaction, in order to reduce any inherent tax risk.
LEVEL OF TAX RISK
The Group is only willing to accept low levels of tax risk, which is in accordance with its commitment to maintain its reputation amongst stakeholders as this is paramount to the business achieving its objectives.
The internal processes and procedures in place, implemented by proficient personnel, are focused on accounting for and paying the correct tax. All Directors and employees are expected to undertake their responsibilities with professionalism, integrity and openness.
The level of tax risk faced and taken by the Group is monitored by the Director of Finance, Senior Accounting Officer and Board throughout the year, as set out above.
WORKING WITH HMRC
The Group maintains an open and transparent working relationship with HMRC and is committed to this continuing.
The Group takes tax compliance very seriously and is fully cooperative in all dealings with HMRC; responding promptly to any queries raised from inspections and enquiries, strictly adhering to all filing requirements and deadlines, making full disclosures and ensuring that all taxes due are settled on or before the due date.
This document was approved by the Board of Directors on 5 March 2024 and was signed on its behalf by:
A Griffith
Chief Financial Officer
