This document sets out the strategic tax objectives of the UK operations of Greenland (UK) Investment Limited, and its UK subsidiaries (collectively described as the “UK Group”). This tax strategy has been approved by the UK Board of Greenland (UK) Investment Limited and satisfies Schedule 19 of the UK Finance Act 2016, in respect of our financial year ending 31 December 2018. The tax strategy set out in this document is tailored towards establishing a clear approach to the various aspects of tax reporting and compliance for the UK operations of Greenland UK. References to “tax” in this document encompasses the following taxes in the UK: corporate tax, income tax, indirect tax, and employment tax.
Taxes covered by this strategy are aligned with the definition of UK taxation in Paragraph 15, Schedule 19 Finance Act 2016, whilst the most material taxes for the Group include corporate taxes, property taxes, employment taxes and indirect taxes.
Greenland UK is part of the Greenland Group, a Chinese publicly traded real estate developer that provides real estate investment services. The Group owns, develops, and manages a variety of commercial, office, industrial, and other buildings, with a focus on high-rise complexes. The Greenland Group is one of China’s leading development companies and has recently expanded investment worldwide including acquiring two high-profile London development sites, the Ram Quarter and another site by Canary Wharf, through the UK Group.
TAX STRATEGY STATEMENT
THE APPROACH OF THE GROUP TO RISK MANAGEMENT AND GOVERNANCE ARRANGEMENTS IN RELATION TO UK TAXATION
Greenland UK’s policy is to comply with all applicable laws, rules, regulations and reporting requirements relevant to the UK Group i.e. paragraph 16(2) of Schedule 19 of the Finance Act 2016. Tax risk management is key to the UK Group and we manage tax in line with our governance framework and risk management procedures which reflects the regulatory, legal and commercial environment in which our businesses operate. We aim to comply with the spirit as well as the letter of the law and seek to pay the right amount of tax, at the right time and in the right place.
Accountability for the UK tax strategy rests with the UK Board along with the overall stewardship of our UK risk management systems and internal control environment. Responsibility for the implementation of the tax strategy rests with the Finance Director, who is supported on a day to day basis by the Finance Department, who receive appropriate training on a continuing basis in order to meet the UK Group’s tax responsibilities. The Board is updated of any significant tax issues requiring its oversight or input as required.
The UK Group has established tax risk management processes that enable the identification, assessment, management and mitigation of key tax risks along with the accurate recording and reporting of tax to HMRC. Where there is uncertainty in how the relevant tax law should be applied, external advice may be sought to support the UK Group’s decision making process, including where necessary, support with our tax compliance filing obligations with HMRC.
THE ATTITUDE OF THE UK GROUP TOWARDS TAX PLANNING (SO FAR AS AFFECTING UK TAXATION)
The UK Group has a robust and comprehensive approach to managing risk which is underpinned by our Code of Conduct (“Staff Handbook”). The UK Group has a low tax risk appetite and our business activities are based on robust commercial and business principles. All decisions are taken after careful consideration of all the issues and potential impacts, including financial, operational and reputational risks.
Tax is a business expense which needs to be managed, like any other. We therefore seek to make use of incentives and reliefs to reduce our tax cost while ensuring that these reliefs are not used for purposes which are knowingly contradictory to the intent of the legislation.
To the extent that the UK Group undertakes any tax planning, it is with the purpose to support the commercial needs of the business and that there is a clear understanding of the tax consequences of any decisions made. This helps to ensure that the UK Group’s business affairs are carried out in a tax efficient manner, whilst remaining compliant with all relevant laws. Consideration is also given to ensuring that any decision is aligned with the business strategy and falls within the overall risk appetite of the group.
Where any tax law is unclear or subject to interpretation, we will engage with external tax advisors to ensure we remain compliant in all our operations.
THE LEVEL OF RISK IN RELATION TO UK TAXATION THAT THE UK GROUP IS PREPARED TO ACCEPT
The UK Group does not have defined levels of acceptable tax risk, but as with other risk, tax is managed within the overall risk framework and risk appetite of the group.
Our risk management system and internal control framework provides an methodology for managing tax risk in relation to the Group’s own affairs. This framework is structured to deliver a level of governance and oversight which is consistent with our risk appetite. This framework is subject to periodic, independent review by our outsourced internal audit function.
THE APPROACH OF THE UK GROUP TOWARDS ITS DEALINGS WITH HMRC
We seek to have an open, honest and positive working relationship with HMRC. We respond clearly and promptly to queries raised, providing appropriate disclosure of corporate information where applicable. We operate with integrity in our tax compliance and reporting, and as an organisation we strive to ensure we adhere to our compliance obligations.
Where areas of uncertainty arise or tax law is subject to interpretation, we are proactive in seeking confirmation of our approach with HMRC, either directly or through our external tax advisors to achieve timely agreement and certainty on such issues and to ensure we remain compliant in all our operations.
Maintaining a positive working relationship with HMRC helps to ensure we are able to facilitate paying the correct amount of tax at the right time, so as to minimise our tax risk and have certainty over our tax filings