Munich Re Specialty Group Ltd – UK Tax Strategy for the year ended 31.12.2020
Our UK tax strategy sets out Munich Re Specialty Group Ltd’s approach to managing tax risk and compliance. The document is published to comply with the requirements of paragraph 19 Schedule 19 Finance Act 2016 and it aims to provide clarity on Munich Re Specialty Group’s risk appetite and its approach to managing tax risk for both internal and external users.
At Munich Re Specialty Group (see Appendix for complete list of companies), we attach great importance to responsible and sustainable company management. Corporate Governance as well as sustainable risk management direct our day-to-day actions and help determine our long-term strategic decisions. In addition, Corporate Responsibility is an essential component of our Group and our strategy is built on “Company success through responsibility”. Munich Re’s (our parent company’s) Code of Conduct binds our management and staff to engage in ethically and legally impeccable conduct.
In terms of our attitude towards taxation, Munich Re Specialty Group is a fair and reliable partner to its clients, its employees, its shareholder and all other external regulatory compliance parties (including HM Revenue & Customs (“HMRC”)). We are committed to acting in a prudent and responsible manner. We are an open, transparent and dependable taxpayer. Further information regarding our approach to tax matters globally can be found in Munich Re’s Tax Transparency Report 2019 which is also publicly available on https://www.munichre.com/en/company/corporate-responsibility/download-center.html.
Our approach to risk management and governance arrangements in relation to taxation
As taxation is a key element in meeting our wider business objectives the Directors of our various UK business operations provide leadership in respect of our approach to taxation. In addition, as some of our businesses are regulated in the UK (by PRA, Lloyd’s and FCA), we ensure that tax risk management is embedded as part of our wider Enterprise Risk Management procedures as well as the new Senior Insurance Manager Regime requirements, where applicable.
From an operational perspective, we have processes in place for identifying and addressing current and future tax risks across the full ‘record to report’ life cycle. This involves engagement with all key internal stakeholders (e.g. Finance, HR and Tax). Where appropriate, senior level committees provide regular oversight. Due to our international corporate structure, we ensure that we remain connected on a global basis and that appropriate arm’s length pricing is in place for cross border transactions.
Our internal review system (and as appropriate, use of external assistance) supports the various Senior Accounting Officers in certifying to HMRC that we have appropriate tax accounting arrangements. Additionally, all tax returns and other submissions to HMRC are checked and validated internally prior to submission (the exception being IPT which is outsourced to Lloyds in line with the rest of the market). Where we consider that we do not have the necessary in-house resource to fulfil our tax compliance obligations, we appoint external advisors to help manage this tax risk.
Where appropriate, we seek to utilise tax authority approved structures to facilitate our business. We obtain advice from appropriately qualified external advisors on specialist UK and non-UK tax matters such as transfer pricing, direct and indirect tax and employment tax matters. This supplements the skills of our own Finance team in appropriate cases. In addition, for all UK taxes we ensure adequate training is provided to help identify new and emerging risks. For all tax processes there are clear accountability, reporting and escalation lines in place with Group Tax in Germany and with the Head of UK Tax in London.
We are committed in respect of all areas within our control to strive for a “low risk” rating from HMRC.
Tax risk appetite
As with our broader business risk appetite we have a low tolerance towards tax risk (across all taxes) and do not make use of tax planning which does not support genuine commercial activity. We seek to minimise the risk of a dispute with HMRC by being open and transparent about our tax affairs and by engaging on a real-time basis.
The tax consequences of significant transactions (including internal restructuring and changes to IT systems) are considered by the senior stakeholders (including our UK tax specialists and Group Tax) as part of their deliberations on the transactions in question. Wherever relevant we would also seek the opinion of external advisors to ensure that the tax impacts of any transaction are aligned with our corporate responsibilities.
We manage our ongoing and future tax risk by meeting regularly with HMRC to discuss significant current and recent transactions and to share details of any proposed significant transaction with them prior to implementation. In cases of significant uncertainty, we would seek advance clearance from HMRC.
Our approach towards our dealings with HMRC
We are committed to maintaining an open, transparent and collaborative approach in our dealings with tax authorities. In the UK, we engage with HMRC through our Customer Compliance Manager to discuss our tax affairs on a timely basis. Across all taxes we strive to ensure, wherever feasible, consistency in approach and reporting across all the different UK businesses.
We take care to ensure that our tax affairs are reported accurately. If in the unlikely event that we identify an error in a submitted tax return, we would seek to voluntarily disclose it to HMRC.
In summary, Munich Re Specialty Group is committed to ensuring it pays the right amount of tax in the UK and other territories and to working collaboratively with HMRC to ensure it is considered a low risk business.
Country by country reporting
This is part of the OECD (Organisation for Economic Co-operation and Development) initiative to require large multinational enterprises (MNE) to report details of taxes paid in each territory where they have a permanent establishment (PE) and to enable these territories to share the information. This is applicable to all MNEs having consolidated annual revenue greater than €750 million. The Munich Re Group falls into this category and therefore all group companies must comply with the Country by Country reporting requirements.
The information will be coordinated on behalf of the group companies across the world by Munich Re AG (the parent) and submitted to the Finanzamt Muenchen, Abteilung Koerperschaften (German tax authority) who in turn will share it with the relevant tax authorities e.g. HMRC. The Munich Re Specialty Group companies are required to provide Munich Re AG with the necessary information. The relevant tax authorities e.g. HMRC also need to be notified that the information will be filed centrally by Munich Re AG in Germany.
List of companies covered by the tax strategy
- Munich Re Capital Ltd (including Syndicate 457, Syndicate 1840)
- Munich Re Syndicate Ltd (managing agent)
- Roanoke International Brokers Ltd (RIBL)
- NMU (Specialty) Ltd
- MRSG UK Services Ltd
- Groves, John & Westrup Ltd (GJW)
- Munich Re Specialty Group Ltd
- Munich Re Capital No. 2 Ltd