UK Group Tax Strategy

1. Introduction

1.1 Group Overview

This strategy applies to Glen Electric Limited and its UK subsidiaries in accordance with paragraphs 19 and 25 of Schedule 19 to the Finance Act 2016. In this strategy, references to the UK Group relate to Glen Electric Limited and its UK subsidiaries as set out in Appendix I.
The principle activity of the UK Group is the manufacture and sale of heating, renewable energy, cooking, cooling and other domestic appliances. The UK Group is part of a leading international group known as the Glen Dimplex Group. The Group is headquartered in Ireland. The UK Group’s tax strategy is governed by the Glen Dimplex Group Board.

1.2 Aim

The UK Group is committed to full compliance with all statutory obligations and full disclosure to relevant tax authorities. The UK Group’s tax affairs are managed in a way which considers the Glen Dimplex Group’s wider corporate reputation in line and with the its overall high standards of governance.
This tax strategy applies to all UK taxes applicable to the UK Group and applies from the date of publication until it is superseded. It will be reviewed annually, updated as appropriate and approved by the Board.

2. Governance

2.1 Governance in relation to UK taxation

  • Ultimate responsibility for the UK Group’s tax strategy and compliance rests with the Board of the Glen Dimplex Group;
  • Executive management of the Glen Dimplex Group and the Glen Electric Group is delegated by the Board to the Group Chief Executive Officer;
  • The Group Chief Financial Officer is the Board member with executive responsibility for tax matters;
  • The Board ensures that the UK Group’s tax strategy is one of the factors considered in all investments and significant business decisions taken;
  • The Group Chief Financial Officer reports to the Board on the UK Group’s tax affairs and risks as and when there is a significant item.
  • Day-to-day management of the UK Group’s tax strategy and compliance is delegated to the Group Head of Tax, who ultimately reports to the Group Chief Financial Officer;
  • The Glen Dimplex Group’s tax team is staffed with appropriately qualified individuals;
  • Each of the UK Group’s trading entities has a local Finance Executive who has joint reporting responsibility to the entity’s Chief Executive and to the Group Chief Financial Officer;
  • The Finance Executive has responsibility to report tax sensitive queries to the Group Head of Tax who will raise material tax related risks to the Group Chief Financial Officer where required.

2.2 Risk Management

  • The Glen Dimplex Group’s business activities are conducted according to high standards of corporate and individual behaviour recognising the critical importance of these standards for the long term profitability and well-being of the Glen Dimplex Group;  
  • The Glen Dimplex Group tax strategy is to manage all taxes to provide a sustainable and competitive outcome in the context of its commercial needs while protecting Glen Dimplex Group’s brand and reputation.
  • The Glen Dimplex Group operates controls as a component of the overall internal control framework applicable to the Glen Dimplex Group’s financial reporting system;
  • As part of the Glen Dimplex Group, the UK 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;
  • Corporation Tax compliance is managed by the Group Tax function. All other tax filing requirements are managed on an individual company level following group standard policies and procedures developed with Group Tax and reviewed by external advisors. Each UK company reports against budget to the Group Board on a monthly basis.  Deviations from budgeted activity are discussed and the tax implications of new projects/developments are considered as part of the budgeting and reporting process.
  • The CFO and the Head of Tax will ensure that appropriate level of oversight and involvement of the Board is maintained.
  • The local Finance Executive is responsible for ensuring that appropriate operational controls are in place to ensure back up documentation is maintained to fully support all tax returns.  The local Finance Executive must also review and signoff the relevant backup documentation to ensure that returns are being properly prepared and submitted on time;
  • Finance Executive responsibilities include the following:
    • Observe all applicable laws, rules and regulations in all business locations;
    • Apply professional care and judgement to arrive at well-reasoned conclusions;
    • Ensure that all decisions are taken at an appropriate level and supported with documentation that evidences the facts, conclusions and risks involved;
    • Where tax law is open to interpretation, the Finance Executive should liaise with the Group Head of Tax and seek, as applicable, written advice or confirmation from our third-party advisors prior to taking decisions; and
    • Undertake all dealings with tax authorities in a professional courteous and timely manner and foster good working relationships.
  • Appropriate training is carried out for finance staff who manage or process matters which have tax implications;
  • The Glen Dimplex Group Tax team seeks advice from its external advisors where appropriate.

3. Attitude towards tax planning and level of risk

The Glen Dimplex 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, Glen Dimplex Group seeks to take advantage of available tax incentives, reliefs and exemptions in line with, and in the spirit of, tax legislation. Tax planning will be undertaken to meet the commercial needs of the Group. However, the Glen Dimplex Group does not undertake aggressive tax planning which is not in line with the letter or the spirit of the relevant tax law. In this regard, the Glen Dimplex Group does not engage in artificial transactions whose sole purpose is to give rise to a tax advantage.
The Glen Dimplex Group complies with relevant tax law and will comply with relevant legal disclosures and approval requirements required by tax authorities.
Advice from external advisors will be sought on particularly high risk areas and material tax transactions whose tax treatment are uncertain. This is of paramount importance to the UK Group’s tax strategy.
The level of risk which Glen Dimplex Group accepts in relation to UK taxation is consistent with its overall objective of achieving certainty in the Glen Dimplex Group’s tax affairs. At all times Glen Dimplex 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 any specific issue or transaction, the Board is ultimately responsible for identifying the risks, including tax risks, which 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.

4. Relationship with HMRC

The UK Group seeks to have a transparent and constructive relationship with HMRC through written or verbal communication in respect of developments in the UK Group’s business, current, future and retrospective tax risks, and interpretation of the law in relation to all relevant taxes. All such dealings will be undertaken in a professional, courteous and timely manner.
The UK Group will ensure that HMRC is kept aware of future significant transactions or transactions where the tax treatment is uncertain. The UK Group interprets tax law in line with the principles contained in section 3 above. The UK Group will liaise with HMRC in interpreting the law if necessary and will seek pre-transaction clearance if required.
Any inadvertent errors in submissions made to HMRC will be fully disclosed as soon as reasonably practicable after they are identified in line with UK tax law. The Glen Dimplex Group seeks an open dialogue and good working relationship with tax authorities and governmental departments in all business locations.


Approved 24 September 2018

APPENDIX I

List of entities covered by this Tax Strategy

  • Glen Electric Limited
  • Morphy Richards Appliances Limited
  • Morphy Richards Limited
  • Belling (1992) Limited
  • Nobo Heating UK Limited
  • Belling Appliances Limited
  • Ability Projects Limited
  • My Green Heating Finance Limited
  • Burco Dean Appliances Limited
  • Applied Energy Products Limited
  • Redring Xpelair Group Limited
  • Halstead Boilers Limited
  • Glen Dimplex NI Limited
  • GDC Group Limited
  • Seagoe Technologies Limited
  • Unidare Environmental Limited
  • Berry Magicoal Limited
  • Dip Limited
  • Stoves Group Limited
  • Roberts Radio Limited
  • Precis (521) Limited
  • Glen Dimplex Home Appliances Limited
  • Lec Refrigeration Limited
  • The UK branch of Glen Dimplex Ireland Unlimited