This document outlines Civica’s tax strategy in accordance with Schedule 19 of the Finance Act 2016 and concerns the financial year-ended 30 September 2021. All references to tax and taxation concern taxes listed in paragraph 15(1) of Schedule 19, and Civica regards this publication as complying with the duty under paragraph 16(2).
Responsibility for Civica’s tax strategy lies with the Civica Group Board. The Chief Financial Officer, and Senior Accounting Officer, is responsible for its implementation and control. Day-to-day responsibility lies with the UK Group and Divisional Finance teams.
Our tax strategy objectives are to fully comply with all regulatory and statutory obligations, and full disclosure to HMRC as openly and transparently as possible, in accordance with our tax principles (see below).
Tax Risk Management
The UK Group manages tax risks via recognition and monitoring of the various types of risk and in accordance with the Group’s tax principles. Tax risks include compliance risks, operational risks and transactional risks.
Careful attention is given to ensure that all tax returns are accurate and are filed on time. To do so, our Finance and I.T teams maintain robust financial systems which are regularly subject to internal and external and audit and control processes, and we engage external compliance advisory services when required.
Finance teams across the organisation’s trading operations work very closely with operational teams. As a result, commercial, financial and operational decisions are taken after proper cross-functional discussion and communication.
The UK Group’s principal activities are the provision of business-critical software and digital solutions, primarily to the public sector and regulated markets in the UK. Therefore, the vast majority of the UK Group’s trading operations are conducted with UK-based Customers and Suppliers. Where the UK Group engages in intra-Group cross-border sales our tax strategy recognises transfer pricing and arm’s-length requirements under OECD guidelines, as a result of which, external transfer pricing advice is engaged as appropriate.
In addition to the more day-to-day compliance and operational risks faced, less routine transactional risks are faced from time to time. These primarily concern acquisitions. Tax risks of acquired businesses, both pre- and post-acquisition are addressed via tax due diligence reviews and reports.
Full compliance with our tax objectives and tax principles helps to ensure that we maintain high standards of corporate social responsibility and enhances our reputation in the communities and markets we serve.
Our over-riding tax principles are to:
- Comply with all rules, regulations and disclosures required;
- File all returns in full and on time;
- Pay all taxes due on time;
- Be co-operative, open and honest;
- Provide information with clarity and transparency;
- Conduct tax planning only in line with normal commercial objectives; and
- Never engage in aggressive and evasive tax planning.
Attitude Towards Tax Planning
We plan in accordance with legislation and our attitude towards tax planning is entirely consistent with our tax objectives and tax principles.
Level of risk in relation to UK Taxation
We do not knowingly take any tax risks. Civica UK’s approach to tax risk is simple; i.e. to always do our utmost to ensure compliance by filing tax returns on or before the due dates and by paying all PAYE, National Insurance, VAT, Corporation and other taxes on or before the due dates.
Wherever we are unsure as to any tax position or uncertainty, we engage external advice from reputable professional tax advisory and compliance companies.
Approach towards dealings with HMRC
We aim to be collaborative, honest, open, timely and transparent in all of our dealings with HMRC. We seek to liaise with HMRC to discuss any tax issues or risks arising either directly or via external advisors.