UK Tax Strategy
This strategy applies to Berlin Packaging Holding UK Limited and its subsidiaries (“the UK Group”).A list of the entities to which it applies is set out below.Berlin Packaging Holding UK Limited is an indirect subsidiary of Berlin Packaging L.L.C.Berlin Packaging L.L.C. and its subsidiaries are referred to collectively as the “Berlin Packaging Group.”
It is published in accordance with Schedule 19 of the Finance Act 2016 (“the Schedule”), as part of the duty imposed on Berlin Packaging Holding UK Limited, as the head UK Company, to prepare and publish a UK Sub-Group Tax Strategy under paragraph 19(2) of the Schedule in the current financial year ending 31 December 2017 and has been made available to be freely accessed by the public online.
This content of this document is relevant as at the date of publication and will be updated when necessary.
References to ‘UK Taxation’ are to the taxes and duties set out in paragraph 15(1) of the Schedule which include Income Tax, Corporation Tax, PAYE, NIC, VAT, Insurance Premium Tax, and Stamp Duty Land Tax, Stamp Duty and Customs & Excise Duties. References to ‘tax’, ‘taxes’ or ‘taxation’ are to UK taxation and to all corresponding worldwide taxes and similar duties in respect of which the Group has legal responsibilities.
This strategy is aligned to the global tax strategy of Berlin Packaging Holdings Italy, SPA, the immediate parent of Berlin Packaging Holding UK Ltd.
The UK Group is committed to and guided by the principles of:
- Transparency in our approach to tax and our dealings with HM Revenue & Customs (“HMRC”)
- Timely and accurate filing of tax returns and other tax obligations
- Promptly paying our taxes in line with applicable laws and regulations
- Having responsibilities at the most appropriate level.
The UK Group CFO is responsible for implementing the UK tax strategy which is aligned with the Berlin Packaging Group strategy, although the board of directors of each company comprising the UK Group (each, the “Board”) as a whole are accountable, as part of the general corporate governance process.
Day-to-day management of the UK Group’s tax affairs is the responsibility of the UK Group CFO who consults with external tax advisers.
Approach of the Group to risk management and governance arrangements in relation to UK taxation
The main tax risks are linked to the fact that the group operates in many different countries, which means that the tax matters can be very complex.The UK business leaders advise the UK Group CFO of UK operations.The UK Group CFO identifies and manages tax considerations resulting from business activities with the help of external experts and escalates matters to the Board when relevant.
Tax provisions are measured and based on the group’s best estimate based on the information available.
The UK Group does not promote any form of tax evasion.The annual financial results are externally audited by an independent, reputable firm of auditors.The UK Group’s tax affairs are also outsourced. The UK Group has the necessary experience and skills set to ensure our compliance obligations have been met and also any Corporation Tax assessments are accurate.The UK Group’s payroll and VAT compliance is administered internally by the UK Finance Department, overseen by the UK Group CFO and European VAT advisors.To reduce risk, full and regular reconciliations are carried out to ensure these processes are accurately executed and external advice is sought for any ad hoc issues.Additionally, training is provided to ensure that the individuals within the UK Finance Department who carry out the payroll and VAT matters are qualified.
The UK Group CFO ensures the Board maintains a close involvement in overseeing the UK Group’s tax affairs, to ensure these are conducted in accordance with the principles of internal governance.
Attitude towards tax planning and level of risk
The Berlin Packaging Group has a low risk approach to tax and does not engage in artificial tax arrangements.This approach is driven by internal governance.
The UK Group utilizes tax relief and incentives in accordance with the spirit of the underlying legislation.
The UK Group follows all necessary steps to deliver accurate tax returns and determine the correct tax treatment across all of our business transactions, to ensure we pay the right amount of tax at the right time.In the rare occurrence that errors are subsequently identified, the UK Group rectifies those errors as soon as practically possible.
External tax advice is sought to ensure the UK Group meets its tax obligations accurately and punctually.
Approach to dealings with HMRC
The UK Group maintains an open and transparent relationship with HMRC.
All dealings with the tax authorities and other relevant bodies are conducted in a collaborative and timely manner.
All tax returns and reports are filed with HMRC electronically.The UK Group is committed to reducing tax risks (past, present and future) and regularly engages with an outsourced tax adviser to ensure any areas of contention are resolved and disclosed appropriately.
Under the UK’s self-assessment regime, it is the UK Group’s responsibility to ensure tax laws are interpreted as intended by Parliament.The UK Group’s approach is to seek the advice of an outsourced tax adviser and obtain an opinion (informal or on a statutory basis) from or make appropriate disclosures to HMRC, if in any doubt.
List of entities covered by this Tax Strategy included in the UK Group
- Berlin Packaging UK Ltd
- The Bottle Jar Store Company Ltd
- Berlin Metal Packaging UK Ltd.