Network Aviation Group Limited
Group Tax Strategy FY2021 – Schedule 16, Finance Act 2016
The Network Aviation Group is a UK qualifying group in accordance with Schedule 16 of the Finance Act 2016, and as such is required to publish its group tax strategy for the group for the financial year ending 31 December 2021.
This document has been approved by the Board of Directors of Network Aviation Group Limited who regard its publication as complying with the duty under paragraph 16(2) in the current financial year and applies to all group and subsidiary companies based in the UK and overseas. A full list of group companies can be found in the group of companies’ accounts for Network Aviation Group Ltd. (Reg. No. 08339061) published on the Companies House website.
Group Tax Strategy Overview
The Tax Strategy of the group is based around the following key objectives:
- To apply risk management and governance arrangements that ensure the highest level of compliance in relation to UK taxation, and all relevant tax laws in any country in which the group operate
- To avail the group of tax exemptions and incentives permitted under UK legislation, and where not in conflict with UK legislation utilise relevant local tax exemptions and incentives permitted under the local legislation in any other country in which the group operates.
- To be fully transparent and have open and collaborative dialogue with HM Revenue & Customs (HMRC) in the UK and the local tax authorities in any other country in which the group operates.
- To operate internal tax compliance processes and controls that will ensure the group is fully tax compliant, and to continually review and adapt our procedures in response to any relevant legislative changes.
Approach to Tax Risk Management and Governance
The Board of Directors of Network Aviation Group Limited has ultimate responsibility for the tax strategy of the Group. Operational responsibility for tax compliance lies with the Group Finance Director.
The Group engages local tax specialist firms in the UK and all other tax jurisdictions in which it operates, to ensure the group is aware of any changes to local tax legislation as well as the impact these changes could have on the Group’s tax submissions. These firms not only provide local tax advice but will also draft the local annual direct income tax computations and submissions based upon information provided by the group’s finance team. These are reviewed by senior members of the finance team for accuracy prior to submission.
A similar approach, engaging local tax specialist firms, is taken in the UK and other tax jurisdictions for all indirect payroll and other indirect tax submissions.
The Group believes the use of specialist tax advisors working in collaboration with senior members of the finance team is the best way to ensure our key tax compliance objectives are met consistently, and the risk of non-compliance is minimised.
In addition, 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 within the United Kingdom and other tax jurisdictions in which we operate.
Processes relating to different taxes are periodically reviewed by senior finance staff to identify key risks and the effectiveness of the 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.
Attitudes Towards Tax Planning
The group will avail itself of tax exemptions and incentives permitted under UK legislation, and where not in conflict with UK legislation utilise relevant local tax exemptions and incentives permitted under the local legislation in any other country in which the group operates.
The group manages risks to ensure compliance with legal requirements in a manner which ensures payment of the right amount of tax. The Company’s attitude towards tax planning is consistent with its key tax strategy objectives and will only seek to take advantage of generally accepted tax incentives, tax relief and exemptions in line with, and in the spirit of, tax legislation where relevant to its commercial transactions.
Level of Tax Risk
For a group of our size and diversity, the level and complexity of tax legislation, combined with the volume of different taxes across jurisdictions in which we operate will always pose a tax risk.
However, through the extensive use of external specialist tax advisors and experienced internal staff, the continual review of tax compliance processes, and the adoption of a groupwide prudent approach to tax, management believe it has maintained, and will seek to continue to maintain by continual review, a low level of tax risk.
Approach towards HMRC
The group seeks to have a transparent and constructive relationship with HMRC and to co-operate fully with any enquiries with responses in a timely manner.
We will continue to proactively ensure any errors identified in submissions to HMRC are fully disclosed as soon as reasonably practicable after they are identified. When submitting Corporation Tax Returns and tax computations to HMRC, the Group will disclose all relevant facts and identify any transactions or issues where it considers that there is potential for the tax treatment to be uncertain.
Now that the combined turnover of the UK entities within the Group has exceeded £200 million for the first time in the year ended 31 December 2020, and as such for the year ended 31 December 2021 the group will be required to submit its Senior Accounting Officer (SAO) self-certification to HMRC in 2022 indicating that we have in place adequate tax controls and tax processes, we will be carrying out further reviews to test our tax compliance processes and controls continue to be robust and effective.
We look forward to sharing the results of this further SAO review with HMRC, along with any further submissions as required by UK legislation or where specifically requested by HMRC.