Bertram Group – Tax Strategy

December 2018

Purpose of Tax Strategy document

The purpose of this document is to outline the approach adopted by the Bertram Group Limited and its subsidiaries in managing its tax obligations and activities across the business.

This strategy is published pursuant to Schedule 19 of the UK Finance Act 2016 and was approved by the Board of Directors on 5 November 2018.

This Tax Strategy document relates to the financial year ended 31 December 2018.


The management of the Group’s tax affairs on a day to day basis is delegated to the Group Accountant who has the necessary qualifications, experience and skills to manage the Group’s tax affairs.

The Chief Financial Officer (‘CFO’) is the Board member with executive responsibility for tax matters.

The Board has overall accountability for the risk management framework, which includes responsibility for the Group’s tax strategy.

Based on an assessment of risk external tax advisors may be engaged to provide tax technical expertise.

Tax Risk Management

The Group seeks to identify, evaluate, monitor and manage tax risks to ensure that they observe all applicable laws, rules, regulations and disclosure requirements when effectively managing the Group’s tax risk.

The Group uses as framework of systems and processes to ensure that we meet all statutory reporting requirements and that tax returns are accurate in all material respects.

Tax Planning and Approach to Risk

The Group does not engage in any aggressive tax planning arrangements and all transactions must have a primary purpose that is not tax driven.

The Group may seek to use reliefs or incentives when these comply with all applicable tax rules and regulations.

In cases where the tax guidance is unclear or the Group does not feel it has the necessary expert knowledge to assess the tax consequences adequately, external advice may be sought to support the Group’s decision making process.

Managing Relationships with Tax Authorities

The Group seeks to have open, honest and transparent relationships with tax authorities, disclosing relevant information to enable tax authorities to carry out their review and to respond to queries and information requests in a timely fashion.

The Group is committed to seeking to resolve issues with tax authorities in an open, collaborative and professional manner.