Cruden Holdings Limited Tax Strategy

Background and Scope

This strategy applies to Cruden Holdings Limited and to the group of companies headed by Cruden Holdings Limited in accordance with paragraph 16 of Schedule 19 to the Finance Act 2016 (the “Schedule”). In this strategy, references to the “Cruden Group” or “the Group” are to all of these entities. A list of the entities to which it applies is set out in an appendix to this document. The strategy has been published in accordance with paragraph 16(4) of the Schedule.

This strategy applies from the date of publication until it is superseded. References to “UK Taxation” are to the taxes and duties set out in paragraph 15(1) of the Schedule and include Income Tax, Corporation Tax, PAYE, NIC, VAT, Insurance Premium Tax, and Stamp Duty Land Tax, as well as Land and Buildings Transaction Tax. 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.

Aim

The Cruden Group is committed to full compliance with all statutory obligations and full disclosure to relevant tax authorities. The Group’s tax affairs are managed in a way which takes into account its wider corporate reputation in line with the Cruden Group’s overall high standards of governance.

Governance in relation to UK taxation

  • Ultimate responsibility for the Cruden Group’s tax strategy and compliance rests with the Group’s Board of Directors.

  • The Board’s requirement to monitor the integrity of the Cruden Group’s financial reporting system, internal controls and risk management framework, expressly includes those elements relating to taxation.

  • The Group Managing Director is the Board member with executive responsibility for tax matters. Reports are made to the Board on the Cruden Group’s tax affairs and risks when considered appropriate.

  • The Group Managing Director is supported by the Cruden Group’s finance team, which is staffed with appropriately qualified individuals.

  • The Board ensures that the Cruden Group’s tax strategy is one of the factors considered in all significant investments and business decisions taken.

Risk Management

  • The Cruden Group, through its Group and subsidiary Boards, operates a system of tax risk assessment and controls as a component of the overall internal control framework applicable to the group’s financial reporting system;  

  • The Group seeks to reduce the level of tax risk arising from its operations as far as is reasonably practicable by ensuring that reasonable care is applied in relation to all processes which could materially affect its compliance with its tax obligations;

  • Processes relating to different taxes are allocated to appropriate process owners, who carry out a review of activities and processes to identify key risks and mitigating controls that are in place.  These key risks are monitored for business and legislative changes which may impact them and changes to processes or controls are made when required. Appropriate training is carried out for staff outside the finance team who manage or process matters which have tax implications.

  • Advice is sought from external advisers where appropriate, including where uncertainty on significant transactions exists.

Attitude towards tax planning and level of risk

The Cruden Group manages risks to ensure compliance with legal requirements in a manner which ensures payment of the right amount of tax.

When entering into commercial transactions, the Cruden Group seeks to employ available tax incentives, reliefs and exemptions in line with, and in the spirit of, tax legislation. The Group does not undertake tax planning unrelated to such commercial transactions.

The level of risk which the Cruden Group accepts in relation to UK taxation is consistent with its overall objective of achieving certainty in its tax affairs. At all times the group seeks to comply fully with its regulatory and other obligations and to act in a way which upholds its reputation as a responsible corporate citizen. In relation to specific issues or transactions, the Board is ultimately responsible for identifying the risks, including tax risks, that need to be addressed and for determining what actions should be taken to manage those risks, having regard to the materiality of the amounts and obligations in question.

Relationship with HMRC

The Cruden Group seeks to have a transparent and constructive relationship with HMRC. All significant tax risks are identified at the time of preparation of tax returns and, when these are submitted to HMRC, the Group discloses all relevant facts and identifies any transactions or issues where it considers that there is potential for the tax treatment to be uncertain.

Any inadvertent errors in submissions made to HMRC are fully disclosed as soon as reasonably practicable after they are identified. All dealings with HMRC are undertaken in a collaborative and timely manner.

 

Approved by Cruden Holdings Limited Board 15 March 2018

Appendix

List of entities covered by this Tax Strategy

  • Cruden Holdings Limited

  • Cruden Investments Limited

  • Cruden Holdings (West) Limited

  • Cruden Buildings & Renewals Limited

  • Cruden Estates Limited

  • Cruden Homes (West) Limited

  • Baberton House (Securities) Limited

  • Baberton House (Trustees) Limited

  • Cruden Property Investments Limited

  • Cruden Property Developments Limited

  • Cruden Homes (Sales & Marketing) Limited

  • Hart Builders (Edinburgh) Limited

  • Cruden Holdings (East) Limited

  • Cruden Homes (East) Limited

  • Cruden Homes (Residential) Limited

  • Hart Estates (City) Limited

  • Hart Estates (Forthquarter) Limited

  • Hart Estates (Granton Harbour) Limited