The purpose of this UK Tax Strategy is to satisfy the statutory obligation under Schedule 19, Finance Act 2016 and covers the following aspects:
- All UK taxes applicable to Brodie Melrose Drysdale & Co Limited (“the Company” or “Brodies”), Puccinos Worldwide Limited, Coffee Care (South West) Limited and the Massimo Zanetti Beverage Group (“the Group”) are considered in this tax strategy.
- The tax strategy is in line with the company’s own business strategy and corporate social responsibility policy which aims to provide appropriate care and consideration to all stakeholders, including suppliers, customers, employees and the local community.
- It is also reflective of the group’s corporate governance and risk management policies with particular consideration to its reputation and all stakeholders.
The Company regards this publication as complying with the duty under paragraph 22(2) of Schedule 19 to Finance Act 2016 for the current financial year. Updated December 2018.
2. Approach to risk management and governance
The Company and Group aim to enhance shareholder value, however commercial needs will in no circumstances override compliance with all applicable laws. Brodies are committed to managing their tax risks and have established appropriate policies and procedures to ensure the following objectives are met:
- Compliance with all applicable laws and tax regulations to ensure all reporting and disclosure requirements are adhered to and tax payments on a timely basis as required;
- Apply professional due diligence and care in order to manage the risks associated with tax;
- Ensure staff are appropriately trained and decisions are made at the appropriate level; and
- Use relevant incentives, reliefs and other tax planning to minimise the tax costs.
Code of Ethics
Brodies is required to comply with the group’s Code of Ethics which can be found here http://investors.mzb-group.com. The principles and values per the Code of Ethics and how these relate to the Tax Strategy have been detailed below:
|Principles & Values||Code of Ethics compiled with Tax Strategy|
|Lawfulness||To comply with all UK tax laws, regulations, administrative measures and, in general, with all statutory provisions considering taxes.|
|Responsibility||To fulfil all tax obligations including all required reporting and payments by acting responsibly and professionally.|
|Honesty and Fairness||To foster an open and honest relationship with HM Revenue and Customs (HMRC). To ensure the internal regulations of Brodies and external regulations of HMRC are adhered to by complying with all tax procedures and operating manuals.|
|Transparency||To inform and communicate the tax strategy and the importance of tax compliance with all stakeholders in a clear and transparent manner.|
|Integrity||To consider ethics a priority of Brodies and to apply these ethics to all aspects of tax. Any conduct which, albeit seemingly in favour of Brodies, is in contrast with the rules in force or with the Code of Ethics, is not tolerated. Brodies condemns any type of bias and partiality.|
|Reliability||To guarantee, to all stakeholders, Brodies’ tax compliance and tax risk management with its commitments and to ensure that what is promised is subsequently implemented, building trust in the relationship with its stakeholders and HMRC in particular.|
|Impartiality||Not to introduce any type of discrimination based on age, sex, race, ethnicity, nationality, political and/or religious beliefs, whenever in offers or decisions made or in and actions taken toward internal collaborators or third parties.|
|Respect||To build a relationship based on mutual respect between the company and HMRC. No bullying, threatening or conduct intended to influence another individual’s actions against the UK tax law or the Code of Ethics and no conduct that is offensive or that violates individual rights is tolerated.|
|Environment & Safety||To ensure a safe and healthy workplace and to act responsibly towards the environment. To respect and promote all UK tax laws and regulations relating to the environment, safety and health.|
|Quality||To conduct business in accordance with the highest quality standards to allow tax obligations to be met and to avoid irregularities. To seek professional expert advice when necessary in order to ensure technical excellence in all areas of tax.|
|Social responsibility||To be engaged in socially responsible behaviour in accordance with UK tax law in order to contribute to the community wellbeing.|
Systems and Controls
Brodies have established systems and controls in order to manage their tax risk and to ensure their reporting obligations and payments are made on a timely basis. The tax systems and controls are documented and staff are appropriately trained to ensure that they are consistently adhered to. The systems and controls are also monitored on a regular basis to ensure they are still fit for purpose to allow the group to operate efficiently and effectively.
The Company’s attitude towards tax risks and the systems and controls required in order to reduce the risks, is driven by the likelihood of occurrence and scale of impact of each risk. By continually making sure that the systems and controls used are up to date, i.e. when IT functionality is utilised this is reviewed and tested on a regular basis, the Company strive to reduce the level of risks as much as possible.
In line with company law requirements, the Directors ensure that there are adequate accounting records for the Company and take reasonable steps for the prevention and detection of irregularities. The comprehensive accounting records allow the company to meet its tax obligations with accuracy.
The Group also have an Audit and Risk Committee which assists the Board of Directors by giving advice in relation to the system of control and risk management.
The tax strategy provides a guide to the Company’s employees and Directors to ensure they adhere to their key responsibilities and conduct themselves professionally with regards to tax compliance, risk management and planning. The Company and Group are committed to providing its staff within continual training and support to allow them to meet their employment duties and therefore comply with the tax strategy.
The staff at Brodies are provided with formal training from its external IT providers when there are any new developments or updates to ensure the Company maintains accurate records. The external IT provider is also available on call for ad hoc queries and support when needed. The robust IT functionality along with routine training ensures transactions and processes are recorded accurately.
The Group also provide Brodies with structured training to ensure they can understand and comply with the Group’s software.
Attitude to Tax planning
The Company take a balanced view with tax planning and adopt a low risk approach. Further, tax planning must always support underlying commercial objectives and the Group’s Code of Ethics. Brodies continually strive to interpret relevant laws in a reasonable way to ensure all arrangements are in alignment with both the purpose and aim of legislation and HMRC’s guidance. Tax is also reviewed when commercial business proposals are considered to understand the tax consequences and fulfil their obligations when required. When more complex tax issues arise the appropriate professional external advice is sought to allow the Group to fulfil its tax obligations.
3. Working with HM Revenue & Customs
Brodies and the Group have controls and procedures in place to ensure they continually comply with all reporting requirements HMRC and tax payments are made in a timely manner. Brodies consider HMRC to be a key stakeholder and strive to work collaboratively, constructively and with integrity with HMRC in order to foster an open and honest working relationship on a continually basis. If any disputes arise with HMRC, Brodies will conduct themselves in a courteous and professional manner and ensure information is provided with disclosure to HMRC on a timely basis in order to resolve the matter efficiently.