LetterOne (L1) is committed to the highest standards of governance, including transparent financial and tax reporting. L1 strongly believes that pursuing a transparent tax policy is a part of doing business. This is in line with L1’s Code of Conduct. In addition, the interests of all relevant stakeholders – shareholders, employees, governments, suppliers, business partners, and minority investors – are balanced with our policy.
The L1 Tax Director is responsible for our tax policy, which is approved by the main Board and Audit Committees. The L1 Tax Director is also responsible for maintaining and updating this policy and for ensuring that procedures supporting the policy are in place, maintained, and used consistently throughout L1.
To safeguard adherence to its tax policy, L1 maintains a well-educated staff of tax and finance professionals who are in constant contact with L1’s business units and senior management. The L1 Tax Team will provide guidance to the business unit on the tax implications of particular transactions. In addition, L1 makes use of the services of accredited tax advisers at all relevant levels in L1 and has included tax compliance in its internal audit program.
L1 reports and pays taxes in the jurisdictions in which it operates in accordance with all relevant tax laws and regulations. L1 complies with such laws and regulations as well as what we believe to be the spirit of those laws and regulations.
Transactions must be driven by a legitimate commercial purpose and will consider appropriate tax planning when entering into such commercial arrangements. In addition, consideration is also given to the reputation of L1 and to its corporate and social responsibilities.
L1 staff are required to file all the required tax-relevant filings with the appropriate tax authorities in a timely and complete manner. To assure timeliness and completeness, tax filings are monitored through L1’s comprehensive tax control framework, which is regularly reviewed and updated. L1 has a very low tolerance for errors in tax processes, including tax compliance processes.
Transactions conducted between L1 companies located in different countries are conducted on an arm’s length basis and in line with current OECD principles and other local transfer-pricing regulations. L1 has implemented a Transfer Pricing Policy to ensure consistent application of international recharging throughout L1.
Tax risk management
L1 adopts a neutral tax risk position and adheres to very high standards of governance in its approach to managing tax risk. This includes the signoff of complex matters by external advisors. To ensure that tax matters are appropriately addressed in transactional activity undertaken by L1 (both in its corporate capacity and in respect of joint ventures), the L1 Tax Team is notified whenever a transaction is proposed.
The tax positions adopted by L1 must be those, which we are confident are robust and in accordance with relevant legislation, based on the tax laws at the particular time. L1 will obtain external opinions in relation to the level of risk for more significant transactions, and consultation may be sought from a tax authority, if appropriate.
All notifications of tax audits or enquiries must immediately be referred to the L1 Tax Director, who will determine, in consultation with the business unit, the approach to be taken and which advisors to use.
Relationships with governments
L1 aims for open and constructive dialogue with tax authorities, including HMRC, on the basis of disclosure of all relevant facts and circumstances. L1 intends to be clear about all aspects pertaining to its tax position and share these in a transparent manner with tax authorities to achieve upfront certainty on tax matters.
This tax strategy applies to the accounting period ended 31 December 2017. L1 adopts the same tax strategy for its global group and does not alter this policy for the UK. Accordingly, L1 regards this publication as complying with its duties under Schedule 19 of the Finance Act 2016.