Tax Strategy - FY22
Contents
- Introduction
- Approach of the Group to risk management and governance arrangements, including in relation to UK taxation
- Attitude of the Group to Tax Planning (so far as it affects UK taxation)
- Level of risk in relation to UK taxation that the Group is prepared to accept
- Approach towards dealings with HMRC
- External advisers
Introduction
Future is a global platform for intent-led specialist media underpinned by technology, enabled by data; with diversified revenue streams. We help people to do the things that matter in their lives; our content and brands give them a place they want to spend their time while meeting their needs.
Future Plc is a premium listed company on the London Stock exchange and our price comparison business, GoCompare, is regulated by the FCA. In everything we do we reflect the “Our Future, Our Responsibility” commitment to operate as a responsible business, driven by our clear purpose, value and culture, to use our scale and reach to make a positive impact and inspire change.
Nowhere more within our business should this commitment be borne out than in the setting of this tax strategy. As a board we expect, and our shareholders should expect, us to be a responsible taxpayer which takes a transparent approach to the management and control of its tax affairs and to engage openly and honestly with the tax authorities.
This tax strategy was approved by the Board of Directors on 20 September 2022 and is regularly reviewed by the Audit Committee. It is publicly available on Future Plc’s website and is compliant with the UK tax strategy publication requirement set out in Part 2 of Schedule 19 FA 2016. This tax strategy applies to the year ending 30 September 2022 and all subsequent years.
Approach of the Group to risk management and governance arrangements, including in relation to UK taxation
Future’s tax policy and the management of tax risks are assessed as part of the Group’s formal governance processes and are reviewed by the Chief Financial Officer who reports them to the Audit Committee on a regular basis. Day-to-day responsibility for tax sits with the Head of Tax.
As a large UK business, Future falls within the Senior Accounting Officer regime whereby a certification is made to HMRC confirming that appropriate tax accounting arrangements are in place.
Key risks are dealt with through our risk management framework, ensuring that appropriate taxes are paid promptly in each jurisdiction in which we operate and that we safeguard our reputation as a responsible taxpayer.
The risks faced by the Group fall into three categories:
- Tax compliance and reporting risks: These are the risks associated with compliance failures such as submission of late or inaccurate returns, late payment of tax, the failure to submit claims and elections on time or where accounting systems and processes are not sufficiently robust to support tax compliance and reporting requirements. We have implemented a governance risk framework to mitigate these risks, such as a Senior Accounting Officer assurance plan which gives the Head of Tax and the Chief Financial Officer assurance over the accounting arrangement that underpin accurate and timely reporting of tax.
- Transactional risks: These are the risks associated with undertaking transactions without appropriate consideration of the potential tax consequences or where advice taken is not correctly implemented. We seek to mitigate this risk through constant engagement by the Finance and Tax Function with the Executive Leadership and Senior Management teams to understand the Group’s commercial strategy, M&A activity, new products, geographies, and other transactions before they occur, and by seeking appropriate external professional advice on the tax consequences. The group’s centralised approach to management and finance from the UK reduces this risk further.
- Reputational risk: This is the non-financial risk that tax may have an impact on the Group’s relationships with shareholders, clients, tax authorities and the general public.
The Group aims to manage tax risk in a similar way to any area of operational risk. The primary oversight functions are Group Tax and Group Risk and Compliance.
Attitude of the Group to Tax Planning (so far as it affects UK taxation)
The Group endeavours to structure its affairs in a tax efficient manner where there is strong commercial merit, ensuring compliance with applicable laws and regulations, in a manner which reflects our values and our commitment to be a responsible taxpayer.
Where we do not have sufficient in-house expertise, the Group will seek professional advice on any potential tax planning opportunities, including structural changes, to maximise shareholder value.
Significant tax planning opportunities are to be assessed and approved by the Board or appropriate committee before the Group can implement them. The Group will also seek advance clearance of key transactions and significant structural changes from the relevant local tax authority as appropriate.
Level of risk in relation to UK taxation that the Group is prepared to accept
The Group has a low tolerance to tax risk and will only adopt tax positions that the board considers to be fair and legal.
Approach towards dealings with HMRC
The Group is committed to having an open, honest and positive working relationship with tax authorities, ensuring prompt disclosure and transparency in all tax matters. The Group has positive and constructive working relationships with H.M. Revenue & Customs and other tax authorities. These relationships involve regular meetings to discuss issues and include obtaining advance clearance of key transactions where the tax treatment is uncertain. We strive to resolve any areas of dispute with the tax authorities, adopting a real time working approach, and improving mutual trust.
External advisers
At both Group and local subsidiary level there is a strong level of engagement with local professional tax advisers and the Group will take appropriate advice from reputable professional firms to perform the following:
- Assist with legitimate tax planning opportunities;
- Review material transactions; and
- Review corporation tax submissions.