This document sets out the policy and approach of RWS Holdings Plc (“RWS”) to its UK tax affairs and regards its publication as satisfying the requirements of paragraph 16(2) of Schedule 19 of the Finance Act 2016. It applies to all companies forming part of the RWS UK sub-group and applies to the year to 30 September 2023.
Our UK tax strategy forms part of our wider corporate governance and reporting strategies and takes into account the Group’s wider corporate reputation in line with its overall standards of governance, core ethical behaviours and values.
RWS's approach to risk management and governance arrangements
Our approach to tax risk and governance is owned and endorsed by the Board of Directors and responsibility for its overall implementation rests with the Group’s CFO. Responsibility for day-to-day tax risk management and governance is delegated to the Group Head of Tax, with the support of the wider finance function.
We have policies in place that enable the Group to identify, manage and mitigate tax risks. Identified tax risks are actively managed within an appropriate tax risk framework and control procedures.
As part of our internal business process, the tax function is involved in or notified of business decisions regarding large or complex commercial deals. Any assessment of tax risk will be determined through professional due care and diligence so that decisions or judgments are made on the basis of reasoned consideration. Some of the factors which would be considered in reaching a conclusion are as follows:
- Legal and regulatory duties of directors and colleagues;
- Impact on the RWS brand and reputation;
- Cost-benefit analysis of the proposed tax treatment in terms of impact on financial performance set against any potential negative impact, economic or otherwise; and
- Impact on future relationship with tax authorities.
We always seek to comply with all relevant laws, rules, regulations and compliance procedures required wherever we operate. Where considered appropriate, advice will be sought from external third-party advisors to help inform the decisions made by us as a business.
We are strongly committed to upholding the values of good corporate governance and accountability to all the Group’s stakeholders including shareholders, colleagues, clients, suppliers and our local communities. Our Code of Conduct provides a clear and straightforward framework for colleagues to use, which allows the business to develop and be run in a sustainable way, building our reputation and minimising risk.
The attitude of RWS towards tax planning
Our approach to tax planning is conservative in nature and reflects the Board's recognition of the importance of high standards of ethical behaviour throughout its business.
We do not engage in artificial tax arrangements, i.e. planning that is not underpinned by commercial and economic substance.
When entering into commercial transactions, we seek to utilise available tax incentives, reliefs and exemptions in line with, and in the spirit of, tax legislation.
When deemed necessary, external advice will be sought in relation to areas of complexity or uncertainty to support us in understanding the tax consequences of its commercial and economic activities and complying with those effects.
The level of risk that the group is prepared to accept
As noted above our position with respect to tax planning and risk management is generally to take a conservative approach, aiming to comply with relevant tax law, rulings and case law. Nevertheless, the nature of operating in a complex, international business environment means that tax risk can never be fully eliminated. We seek to balance tax risk by maintaining a vigilant and robust oversight of our tax reporting processes and by taking third-party advice in areas of particular complexity. Our target level of UK tax risk is also lowered by the Group’s ongoing and consistent aim of filing all tax returns on a timely basis and engaging in an open and honest manner with HMRC.
The approach of RWS in its dealings with tax authorities
We aim to engage with tax authorities in an open, collaborative and transparent manner. RWS believes that such relationships are beneficial to the Group as a whole and minimise the risk of substantial tax disputes arising.
We make the necessary corrections of any material errors or misstatements in tax filings where permissible and/or required by law and practice without undue delay. Any inadvertent errors in submissions made to tax authorities are fully disclosed as soon as reasonably practicable after they are identified.