Generali UK Branch Tax Strategy
Meeting our requirements under Schedule 19 paragraph 16(2) of the Finance Act 2016
Generali UK Branch is the operating entity for Assicurazioni Generali SpA in the UK. The business writes a combination of general insurance, life assurance and employee benefit business. The UK Branch was established in 1963 and specialises in writing corporate risks.
We have set out below our tax strategy and highlighted how this aligns to the commercial activities undertaken in the UK. This strategy is intended to meet our requirements under Schedule 19 paragrah 16(2) of Finance Act 2016.
Governance & Risk Management
At Generali we seek to comply with all relevant tax laws, rules, regulations and reporting and disclosure requirements, wherever we operate.
The UK Branch tax compliance obligations are dealt with at a branch level. As a result oversight and ultimate responsibility for tax compliance falls to the UK Chief Financial Officer and the UK executive committee.
Operational responsibility for tax compliance, risk management and general tax matters (Corporation tax, Value Added Tax, premium taxes, Employment tax matters and PAYE) falls to the finance function (Tax accountant and Head of tax).
Broader tax responsibilities relating to specific tax processes and data requirements may sit within other departments such as Finance, Human Resources, Compliance and Operations. Where this is the case these responsibilities are documented within a governance framework and subject to internal audit or external review on a periodic basis.
The UK Branch maintains an effective system to identify, measure, manage and control the UK tax risk. These measures ensure that a framework consists of ‘process controls’ which provides evidence that proper procedures are in place, in order to guarantee an appropriate and effective internal control system over tax risks. These are reviewed through risk monitoring systems and internal audit reviews to ensure adherence to applicable legal provisions.
The approach to tax risk is consistent with the management of risk across the Generali UK Branch and the organisation as a whole. The tax function provides quarterly updates to the risk team in relation to key tax risks that have been identified. The business does not have a fixed monetary level of acceptable risk but seeks to minimise the risk of operational failure by undertaking the following activities:
Monitoring – The UK tax function is responsible for identifying relevant changes in the tax regime and ensuring systems and processes are updated appropriately. The CFO and the UK tax function are involved in significant business changes in order to confirm that all relevant tax matters have been considered.
Management – Generali continues to develop structured tax controls which are introduced into business processes in order to reduce tax risk. Operation of these controls is performed by relevant departments and reviewed annually by the tax function.
Communication – The UK tax function is responsible for communicating tax risk within the organisation. Tax risks are reported quarterly to the risk function which is consistent with other operational risk matters. Significant tax risks are highlighted to the Board and senior management for consideration.
We have a low tolerance for tax risk and therefore rely on the above control framework to mitigate the risk of operational errors or omissions on and or/late submission of tax returns/ tax payments. When appropriate Generali UK Branch will use external advisers to advise on compliance issues and any significant transactions.
We were categorised in 2017 by HMRC as low risk and our risk status will be reviewed again during 2020/21. As part of this review we have agreed to have regular update discussions with all relevant HMRC representatives.
Our approach to tax planning focuses on the effective management of the Group’s tax position in line with the broader commercial objectives to put customers first and deliver long term economic value.
The UK tax authorities and other tax regimes often include tax credits or exemptions for commercial business activity. Where relevant we will seek to claim these incentives if they are consistent with the commercial objectives of the business and do not create significant risk.
As part of our regular discussions with HMRC we will use this opportunity to disclose any significant tax planning requiring any material technical/interpretation of tax risks. We have a low tolerance to tax risk and if necessary seek external advice by suitably qualified advisers.
Approach towards dealings with HMRC
Generali UK Branch is committed to the principles of openness and transparency in its approach to dealing with HMRC.
We aim to ensure all our tax affairs are reported accurately and in a timely manner. If we were to identify an error we would seek to engage with HMRC proactively, provide relevant information and reach a suitable conclusion.