Our Tax Strategy supports our culture and how we conduct our own affairs. Our culture is built on ethics, individual responsibility, and integrity. We always do the right thing. These principles are the foundation for how we conduct our own affairs.
The Group Board and the Audit & Risk Committee are responsible for the Groups Tax Strategy. The implementation of the strategy is delegated to the Groups Director of Tax & Treasury, who in turn delegates this to the Groups Head of Tax.
The Places for People Group
Places for People Group is one of the largest property and leisure management, development and regeneration group of companies in the UK. The Group owns or manages over 230,000 homes in the UK and provides services to over 500,000 people.
The Places for People Group is made up of specialist charitable and non-charitable subsidiaries working collaboratively to build sustainable communities. Places for People Group Ltd, the parent entity is a non-profit-making company limited by guarantee and a
Registered Provider of Social Housing (A Housing Association).
The group generates the majority of its income from social housing lettings and other social housing activities such as shared ownership sales and the provision of care and support. Collectively, these companies own or manage over 71,000 affordable rented homes.
The Group is one of eight strategic partners working with Homes England to deliver 2,600 new affordable homes over three years. Last year, the Group completed the development of 1,466 affordable homes.
The Group also generates income from non-social housing lettings including market and commercial rent, open market property sales and land parcel sales to facilitate housebuilding. To further complement and supplement this, we provide leisure facilities across the country and prioritise work with our local authority partners to boost health and wellbeing.
The non-charitable companies in the Places for People Group are within the charge to UK corporation tax on their activities.
General Tax Arrangements
The Chief Financial Officer has overall responsibility for the management of the tax affairs of the Places for People Group. This includes the submission of accurate tax returns on a timely basis, as required. The Chief Financial Officer is ultimately responsible for communicating and advising on tax issues and risks to the Board and the Audit & Risk Committee.
The day-to-day management of the Groups tax affairs is delegated to the Group’s Director of Tax & Treasury, who in turn delegates this to the Groups Head of Tax. The Head of Tax leads the experienced in-house tax team who hold a combination of tax/accounting qualifications and sit within the Groups central finance function that reports to the Chief Financial Officer.
The Tax Team is responsible for satisfying all the Groups tax compliance obligations and working diligently towards paying the right amount of tax at the right time. The team ensures that the Groups processes and procedures are established and actively implemented in a way in which the right amount of tax is calculated. This principle applies to the cyclical and routine operations of the Groups business as well as tax liabilities potentially arising from one off transactions.
The approach to compliance is extended to the provision of professional and prompt responses to queries and questions raised by external and internal stakeholders, including HMRC and colleagues.
The Tax Teams behaviour is founded on the following guiding principles:
- Upholding professional standards
- Being transparent and fair
- Fostering a culture of collaboration, and
- Valuing the longer-term consequences of our decisions.
The tax team deals with almost all the Groups need for tax services. This includes the operation and implementation of all tax compliance matters and ensuring they are appropriately delegated within the tax team. Corporation Tax, VAT, SDLT, Employment Tax, and CIS Returns are delegated with appropriate levels of review signoff.
In circumstances where tax uncertainty is identified or where it is considered that there is insufficient internal expertise, the Group will seek external advice to assist with resolving that uncertainty, concluding on the correct tax treatment, and/or to provide a second opinion.
Approach to tax planning
The Places for People Group believes in its obligation to pay a right amount of tax at the right time in accordance with the legislative provisions and guidance issued by HMRC, but also seeks to be efficient with its tax affairs.
The Tax Strategy of the Group is driven by transparency and ensuring that the tax reliefs, allowances, and tax exemptions to which the Group is properly entitled are claimed in the manner intended. We will only look to mitigate a tax liability in this way if it complies with the intention of the law.
Due consideration is given to the Groups reputation, brand, corporate and social responsibilities when considering tax planning, as well as the fiduciary duties of the Group Board, Executive team and employees of the Group. The Group encourages ethical and transparent business practices and actively seek to work alongside other key stakeholders including, HMRC.
All tax planning is built on sound commercial business activity; the Group does not believe in using artificial tax arrangements to take advantage of legal but essentially questionable loopholes in tax legislation. The tax team use their significant and wide-ranging experience to employ routine tax planning always with an emphasis on ensuring that it reflects the commercial substance of the business and/or the particular transaction. For non-routine or complex transactions, the Head of Tax would decide on the appropriateness of the planning and if necessary, this would involve the Director of Tax & Treasury or the Chief Financial Officer.
Managing Tax Risk
The Group recognises that eliminating tax risks entirely is impossible. We therefore seek to reduce the level of tax risk arising from its operations as far is practically reasonable by implementing various internal tools for the business functions to follow. Processes, activities and transactions in relation to different taxes, and the controls relating to them, are reviewed by the appropriate specialist within the tax team to identify key tax risks.
We maintain robust processes and controls across all taxes, which are designed to minimise the risk of errors arising which could impact the amount of tax that we pay. These processes and controls are regularly monitored, reviewed and tested and underpin the submission of all tax returns. Key risks are monitored for changes in business practice, tax legislation, and HMRC guidance. By regularly reviewing its tax affairs and tax risk management procedures, the Group ensures that its Tax strategy continues to be aligned with its overall business strategy and governance framework.
We take a zero-tolerance approach to the facilitation of tax evasion in any form by our employees, agents, or associates of any kind. Reasonable prevention procedures are in place for the purposes of Part 3 of the Criminal Finances Act 2017. Our Corporate Criminal Offence Policy governs the Groups approach and is clearly communicated to all appropriate stakeholders.
There are various measures in place ensuring that the risk of non-compliance or paying excessive amounts of tax including:
- Closely aligning our reporting in relation to the Senior Accounting Officer requirements, so that our processes as they affect tax are monitored on an annual basis by the tax team.
- Undertaking to review the Groups processes and procedures with a view to identifying tax related risks. Our reviews are conducted on a regular basis with the frequency of the reviews being determined by various factors including the quality of the compliance record, previously identified risk areas, actions taken since the last review, complexity and the scale of the amounts involved.
- The tax team conduct a rolling programme of detailed VAT reviews of all businesses within the Group.
- A strong in-house tax team with expertise in a wide range of tax specialists. The tax team is well supported by the wider Finance function in terms of regular and frequent tax training which is so vital in the constantly changing discipline of tax.
- The Group recognises that external specialist tax advisors should be utilised when appropriate, ie, usually on very high value or particularly complex transactions.
- The Executive Board and Audit & Risk Committee are regularly updated on tax risk, developments in tax law and practice for the Group at a strategic level. As it does with other business risks, the Group Board will consider significant tax risks as part of its oversight of the Groups activities.
- A key part of managing risk is the ongoing maintenance of the tax risk register. This assists the Group in the identification and monitoring of risk and ensuring that the appropriate action plan is implemented.
- Pro-active and open communication between the tax team and all stakeholders both within and outside the Group is the most effective means of ensuring that tax risk is monitored and managed as effectively as possible.
Working with HMRC
The Group is committed to a transparent, collaborative, and positive working relationship with HMRC. The importance of managing the relationship with HMRC is not underestimated by the Group. The Head of Tax leads the relationship with HMRC involving regular contact
with our Customer Compliance Manager (CCM) and the HMRC’s Large Business Service. All members of the tax team are encouraged to develop and maintain this relationship.
The Group takes a proactive approach in the event that any inadvertent errors in respect of tax matters are identified, ensuring they are disclosed to HMRC as soon as is reasonably practicable.
We engage openly and constructively with HMRC on matters relating to our tax affairs. We keep HMRC aware, at an early stage, of significant transactions and/or changes in the business which may have significant tax implications.
Tax can be very complex, and we approach our obligations with an appropriate level of analysis and consideration. Where necessary we will seek formal or informal clearance from HMRC on uncertain tax positions. Where we cannot reach agreement with HMRC on the proper interpretation of law, and there is no other practical means of achieving agreement, we may test the matter in the tax tribunals whilst simultaneously collaborating appropriately with HMRC on the conduct of such actions.
Senior Accounting Officer
Finance Act 2009 introduced legislation requiring large companies to certify to HMRC that they are taking reasonable steps to ensure that “appropriate tax accounting arrangements” are in place. Our Senior Accounting Officer Policy governs the Groups approach. The Chief Financial Officer is the appointed Senior Accounting Officer for the relevant entities within the Places for People Group.
Certain specified companies are not included within the SAO regime including Co-operative and Community Benefit Societies. This exclusion means that we do not have to certify for the large Registered Providers within our Group. Whilst we do not have to certify for our Registered Providers, we do maintain the same high level of tax risk management, tax processes and tax accounting arrangements for those companies. The tax team ensures that over 100 companies within our Group are certified under the SAO provisions on an annual basis.