The information below outlines Valassis Limited’s (the “Company’s”) tax strategy and risk management as it pertains to tax reporting for the year ending 31 December 2019 (published pursuant to UK Finance Act 2016).
Valassis Limited is committed to the following:
- Complying with all applicable tax laws and regulations in all jurisdictions in a timely and accurate manner.
- Careful oversight of the processes and procedures involved in all tax related activities performed in the UK and ensuring that its tax governance is appropriate.
- Accurate and timely disclosure on all filings with HMRC. Open and honest dialogue with tax authorities and, where applicable, working with HMRC to ensure reasonable and accurate interpretation of the law.
Risk Management and Governance Arrangements in Relation to UK Taxation
- The Company has implemented various processes across the business to ensure that appropriate governance of compliance with applicable laws and regulations are in place. This includes regular executive meetings, periodic governance reviews, and mandatory training modules for relevant staff in relation to tax governance.
- Company personnel stays abreast of any changes in tax law through legislative updates and attendance at technical updates hosted by 3rd party advisers.
- Segregation of duties is maintained between the preparation and review of tax computations and returns (prepared by 3rd party advisers), which are approved by the Finance Director to ensure accuracy in reporting.
- All tax related documents must be reviewed and approved by appropriate management (typically the Finance Director).
- MacAndrews & Forbes (the US parent of the Company) has access to tax computations and returns, as well as other tax related documents relating to the Company and makes enquiries to satisfy itself of adequate compliance.
Tax Planning (affecting UK taxation)
- The Company has not historically undertaken any tax planning. The Company ensures that it is compliant with all relevant tax laws and regulations and remits the amount of tax it is required to pay.
- Tax is considered during the commercial decision making process and the company seeks relevant input from 3rd party advisers where relevant.
Risk Level Accepted in Relation to UK Taxation
- The Company is risk averse and is conscious of the reputational risks associated with aggressive tax planning. This risk averse attitude is also influenced by the stakeholders of the business (including MacAndrews & Forbes and the Company’s client base). As such, the Company engages 3rd party advisers to ensure appropriate technical tax guidance is provided.
Approach Towards Dealings with HMRC
The Company is committed to the following:
- Accurate and timely disclosure in tax filings and tax payments, query responses, and other HMRC correspondence.
- Resolving tax uncertainties with HMRC, if any, through collaborative discussion, in a timely fashion.
- Working with HMRC in an open, collaborative and professional manner, to ensure reasonable and accurate interpretation of the law to evaluate past, current and future tax compliance.