Tax Strategy

RHI UK Tax Strategy

Scope

RHI Refractories (UK) Ltd, a limited company registered in Scotland, is a wholly owned subsidiary of RHI Feuerfest GmbH. GIX International Ltd, a limited company registered in England, is also a wholly owned subsidiary of RHI Feuerfest GmbH.

This strategy applies to RHI Refractories (UK) Ltd, GIX International Ltd and to the companies headed by GIX International Ltd in accordance with paragraph 19 of Schedule 19 to the Finance Act 2016. A list of the entities to which it applies is set out below. In this strategy, references to ‘RHI UK’, ‘the firm’ or ‘the group’ are to all these entities. The strategy has is being published in accordance with paragraph 16(2) of the Schedule.

This strategy applies from the date of publication until it is superseded. References to ‘UK Taxation’ are to the taxes and duties set out in paragraph 15(1) of the Schedule which include Income Tax, Corporation Tax, PAYE, NIC, VAT, Insurance Premium Tax, and Stamp Duty Land Tax. References to ‘tax’, ‘taxes’ or ‘taxation’ are to UK taxation and to all corresponding worldwide taxes and similar duties in respect of which the Group has legal responsibilities.

Aim

RHI UK is committed to full compliance with all statutory obligations and full disclosure to relevant tax authorities. The group’s tax affairs are managed in a way which takes into account the group’s wider corporate reputation in line with RHI UK’s overall high standards of governance.

Governance in relation to UK taxation

  • Ultimate responsibility for RHI UK’s tax strategy and compliance rests with the Board of RHI UK;
  • Executive management of the group is delegated by the Board to the UK Executive Directors who have responsibility for the day to day management of RHI UK’s tax affairs.
  • The RHI UK finance team is staffed with appropriately qualified individuals;
  • The Board ensures that RHI UK’s tax strategy is one of the factors considered in all investments and significant business decisions taken;
  • The parent entity, RHI Feuerfest GmbH, has a central tax department with tax specialists who provide the Board with advice and guidance as necessary.

Risk Management

  • RHI UK operates a system of tax risk assessment and controls as a component of the overall internal control framework applicable to the group’s financial reporting system;
  • RHI UK 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;
  • Processes relating to different taxes are allocated to appropriate process owners, who carry out a review of activities and processes to identify key risks and ensure that mitigating controls are in place. These key risks are monitored for business and legislative changes which may impact them and changes to processes or controls are made when required;
  • Appropriate training is carried out for the finance team who manage or process matters which have tax implications;
  • Advice is sought from external advisers where appropriate.

Attitude towards tax planning and level of risk

RHI UK 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, RHI UK seeks to take advantage of available tax incentives, reliefs and exemptions in line with, and in the spirit of, tax legislation.  RHI UK does not undertake tax planning unrelated to such commercial transactions.

The level of risk which RHI UK accepts in relation to UK taxation is consistent with its overall objective of achieving certainty in the group’s tax affairs. At all times RHI UK 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.

Relationship with HMRC

RHI UK seeks to have a transparent and constructive relationship with HMRC in the UK through communication regarding significant transactions, where necessary, and interpretation of the law in relation to all relevant taxes.

When submitting tax computations and returns to HMRC, RHI UK discloses all relevant facts and identifies any transactions or issues where it considers that there is potential for the tax treatment to be uncertain.

Any inadvertent errors in submissions made to HMRC are fully disclosed as soon as reasonably practicable after they are identified. All dealings with HMRC are undertaken in a collaborative and timely manner.

 

List of entities covered by this Tax Strategy

RHI Refractories (UK) Limited

GIX International Limited

Indresco UK Limited

RHI Refractories (Site Services) Limited