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Tax Strategy

Bright Topco Limited

Scope

This strategy applies to Bright Topco Limited and to the group of companies headed by Bright Topco Limited (in accordance with paragraph 16 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 ‘BPP’ or ‘the Group’ are to all these entities. This tax strategy was published on 2 August 2024 and BPP regards this publication as complying with its duty under paragraph 16(2) Schedule 19 FA 2016 in its financial year ended 31 August 2023.

This strategy applies from the date of publication until it is superseded.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

BPP 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 BPP’s overall high standards of governance.

Governance in relation to UK taxation

  • Ultimate responsibility for BPP’s tax strategy and compliance rests with the Board of BPP;

  • The Chief Financial Officer (“CFO”) is the Board member with executive responsibility for tax matters;

  • During the year, the directors review matters relating to a variety of areas, including taxation. This is done through regular communication and dialogue with senior management, the consideration of reports and other supporting information as well as engagement with external experts where appropriate;

  • Day-to-day management of BPP’s tax affairs is delegated to the Group Finance Director (‘FD’), who reports to the CFO, and is supported by appropriately qualified staff.

 

Risk Management

  • BPP 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;

  • BPP 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 mitigating controls 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 staff both inside and outside the finance team who manage or process matters which have tax implications;

  • Advice is sought from external advisers where appropriate and external experts form a key element of the tax processes and controls.

 

Attitude towards tax planning and level of risk

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

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

To the extent that there is dialogue with HMRC, BPP seeks to have a transparent and constructive relationship with them.

When submitting tax computations and returns to HMRC, BPP 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.

Entities covered by this Tax Strategy

Bright Topco Limited and subsidiaries (please see Bright Topco Limited financial statements at companieshouse.gov.uk for full list)