Moorfield Group – UK Tax Strategy
This document sets out the UK tax strategy for the Moorfield Group, consisting of Stessa Trading Limited and its UK subsidiaries and the Real Estate Funds which it manages (hereinafter referred to as “Moorfield” or “the Group”).
The document outlines the Group’s policy and approach to conducting its UK tax affairs and managing tax risk. The strategy applies to all UK taxes that the Group is required to account for and which are payable and reportable to HM Revenue & Customs (“HMRC”), including corporation tax, indirect taxes and employment taxes.
The Group’s strategy is defined by this document and sets out our approach to tax, which is to use its best efforts to ensure compliance with all applicable tax laws and regulations, and ensures that due consideration and foresight is given to tax law developments.
Management of tax risks
Ultimate responsibility for this tax strategy and the Group’s overall approach to tax governance in the UK sits with the Board of Directors of Stessa Trading Limited.
Day to day management of the Group’s tax affairs and tax risks is overseen by the Group Finance Director, who will highlight relevant tax matters to the Board of Directors as and when required. The Group Finance Director is supported by the finance team in the day to day management of tax.
In addition Moorfield uses external tax advisors to provide UK tax compliance and advisory services across a range of UK tax areas, and to assist with the identification, quantification and management of tax risks where appropriate.
The Board of Directors considers it has appropriate and proportionate controls and processes are in place to meet Moorfields tax strategy. The Group maintains a tax Risk and Control Matrix to ensure that tax risks are identified and the controls that mitigate these are evidenced and documented.
Attitude to tax planning
In accordance with expectations of the Fund’s Investors, Moorfield will consider tax planning opportunities that prevent double taxation and maximize the after-tax-return for its investors. However, before implementation such planning is carefully considered and the Group will only participate in non-aggressive tax planning. Any planning must align with the Group’s commercial aims and be consistent with the letter and spirit of the applicable law.
The Group defines aggressive tax planning as the exploitation of technicalities in a tax regime or the exploitation of inconsistencies between tax regimes in order to reduce tax liability, and this includes, but is not limited to:
Moorfield works closely with external tax advisors and will take advice from these in cases where the tax analysis is unclear, subject to interpretation, or where there is a significant degree of uncertainty.
The level of risk the Group is prepared to accept for UK taxation
Moorfield recognises that tax revenue forms an essential part of a well-functioning society. The Group’s Investors and other key stakeholders expect the Group to act responsibly and be a good corporate citizen. Moorfield therefore has a low appetite for tax risk in the UK.
Responsibility for quantifying tax risk sits with the Group Finance Director, and support with tax risk quantification will be taken from external tax advisors when considered appropriate.
Working with HMRC
Moorfield aims to act with integrity and transparency in all its dealings with HMRC. The Group aims to work with HMRC in a proactive and collaborative manner to ensure that it meets all of its tax legislative requirements and pays the correct amount of tax at the correct time.