The Nord Anglia Education (“NAE”) group is the world’s leading premium international schools organization. As at May 2018 we have 55 schools in China, Europe and the Middle East, South East Asia and the Americas. The NAE group is headquartered out of Hong Kong.
The UK tax strategy of NAE’s UK group (together “NAE UK”) set out below has been prepared pursuant to Schedule 19 of the Finance Act 2016 (“Schedule 19”). The UK tax strategy applies to UK taxation as defined in Schedule 19.
This document was drafted by NAE’s in-house tax department, with input received from senior executives within the business, and was approved by NAE’s Chief Financial Officer. The UK tax strategy is subject to annual review and will be updated as appropriate.
The approach of NAE to risk management and governance arrangements in relation to UK taxation
The NAE Group has an in-house tax team, based in the Group headquarters in Hong Kong, charged with the day-to-day management of NAE UK’s tax affairs and the setting of tax policies and procedures for the Group. The tax team members have adequate training and skills for the role and complexity of duties they carry out. The Group Head of Tax has responsibility for the tax function and is accountable to the Chief Financial Officer. Ultimate responsibility for managing NAE’s tax risks and tax compliances lies with the Board, with this responsibility delegated to the Chief Financial Officer.
The NAE tax team provide advice to the business on tax-related issues, oversee UK tax compliance-related matters and manage NAE UK’s relationship with HMRC and with third party advisors. The NAE tax team routinely obtain advice from external UK tax advisors, which forms a key part of our UK tax return process.
The NAE group proactively manages, reviews and reports on all commercial risks, including tax risk. The Audit and Risk Committee monitors the effectiveness of the corporate governance, regulatory compliance and internal control framework within the Group, including the tax function.
Given the size of our business and the geographic footprint, it is inevitable that risks may arise with respect to the application of tax laws that are complex and uncertain at times. Where any material tax risks are identified, these are escalated to the Group Head of Tax and the CFO, and reported to the Audit and Risk Committee. The CFO will also update the Board, where required, on material tax matters.
Attitude of the group towards tax planning
The NAE Group is fully committed to conducting its affairs in accordance with the legal, regulatory and tax regulations of the countries in which it operates, including the UK. Any tax planning that is undertaken is based on commercial activity. NAE will not engage in artificial arrangements for the sole purpose of avoiding or reducing tax.
Where there are any decisions to be made in respect of uncertain or complex tax issues, these will be made in consultation with experienced third party advisors. External advice is often sought by the tax function to ensure commercial activities are undertaken in compliance with applicable tax legislation.
Level of acceptable risk in relation to taxation
Given the numerous countries in which we operate and the expansion of the Group, unforeseen tax consequences may be inevitable at times. Where there is significant uncertainty or complexity, external advice is sought and NAE proceeds accordingly.
We do not engage in aggressive tax planning, and do not have a high tolerance for tax risk.
Approach towards dealings with HMRC
Due to our size and limited operations in the UK, we have had limited interaction with HMRC over recent years. However, where it has been appropriate, we have reached out to HMRC before transactions, we respond to queries within the required timeframe and seek to ensure any engagement with HMRC is cooperative, professional, transparent and honest.