At esure we are committed to paying the correct amount of tax when it is due. We understand that this is part of our contribution to Society and is expected by both our shareholder and policyholders. We pride ourselves on our wider strategy to ‘Fix Insurance for Good’ and believe that our principled approach to tax forms a part of that.
2023 Group Tax Strategy
Our tax strategy is aligned to our overall Group strategy. We will:
- Meet our legal and compliance requirements relating to UK and overseas tax;
- Recognise our responsibilities as a business towards the wider community and not engage in tax planning that is outside the letter or the spirit of the law;
- Consider tax as part of major business decisions;
- Consider the impact on the Group’s reputation;
- Operate effective governance and risk management; and
- Engage constructively with HMRC.
Managing Tax Risk
The Board is responsible for ensuring the maintenance of an effective system of internal control and risk management; to assist the Board in carrying out its functions and to ensure there is independent oversight of internal control and risk management, the Board has delegated certain responsibilities to Board Committees. The risk reporting as part of the risk management framework and Own Risk and Solvency Assessment (“ORSA”) process are designed to ensure that the Board Committees receive timely and appropriate reporting on the Group’s exposure to existing and emerging risks; tax risk is considered alongside other business risks as part of this wider governance process, but is not currently considered a material risk for the Group. Our risk appetite with respect to tax risk remains low.
As part of this, the Group regularly reviews its tax affairs, and when we consider material changes to the business, or to our tax planning, or identify forthcoming changes to tax legislation, we obtain external advice to ensure we identify, manage and mitigate risk.
The Chief Finance Officer is responsible for tax strategy, policies and management of tax risk.
The Risk Management function performs a second line of defence role, providing independent and objective challenge to the business in the effective operation of the risk management system.
We are subject to various taxes including corporation, employment and indirect taxes (including IPT and VAT). Where there are up-coming legislative changes or significant business change we take external advice to ensure that our approach is compliant whilst continuing to deliver value for our shareholder. The Group will only enter into transactions which are commercially driven but will claim tax reliefs and incentives where available and appropriate.
esure’s Tax Risks
The primary tax risks faced by the Group have been identified as:
- Changes in legislation – the UK tax landscape is changing rapidly, as such there is an underlying risk that we do not identify changes in legislation pertinent to the Group. We mitigate this risk through our annual review, on-going relationships with external tax advisors and as part of trade bodies including the ABI.
- Transactional risk – when the Group undertakes material one-off transactions we aim to understand the tax implications before the transaction is approved. We engage with HMRC as appropriate to mitigate material risks identified.
- Compliance and reporting risk – to ensure we meet our tax compliance obligations we have the right resources and governance in place to enable us to complete tax returns and make tax payments accurately and on time, including the use of external advisors where appropriate.
- Reputational risk – we consider the reputational impact of any tax structuring, including in how we report and pay tax. We are committed to operating within our tax strategy.
Working with HMRC
We work with HMRC in an open and timely manner and with due regard to the HMRC Framework for Co-operative Compliance, to ensure that we meet all our tax obligations both in relation to direct taxes and also to the collection of taxes on behalf of HMRC in accordance with prescribed rules and deadlines. This includes, where appropriate, discussions with HMRC relating to significant transactions and the implementation of new legislation.