This Tax Strategy is applicable to the tax activities of the UK entities1 related to the Kedrion Group (‘Kedrion’ or ‘the Group’) as they relate to UK taxation.
This disclosure is made in compliance with the duty of the Group (trading as BPL in the UK) to publish its tax strategy in accordance with section 161 and paragraph 19(4) of Schedule 19 of the Finance Act 2016 in the current financial year. It is effective for the accounting period ended 31 December 2023
The Kedrion Group (headed by Kedrion Holding S.p.A) is ultimately majority owned by funds advised by the Private Equity firm Permira (“Permira”) which acquired a controlling stake in the business on 31 August 2022. Permira has structured its investment in the business through Permira VII Investment Platform Limited, a holding company that has investments in businesses across a number of different activities and geographies, including the UK. Whilst this tax strategy document applies to Kedrion, it is aligned with the principles set out in the tax strategy document published by its parent company, Permira VII Investment Platform Limited.
As an organisation, we are committed to acting with integrity in how we undertake our activities and in all our business dealings. This UK Tax Strategy document seeks to align to this commitment in how we carry out UK tax activities across the organisation.
Tax Compliance and Reporting
We are committed to meeting all our legal and regulatory requirements in paying the correct amount of tax and meeting our tax compliance obligations. Compliance with all laws and regulations, including those relating to tax, is embedded in the culture of the business and we have an established internal control system and procedures to help achieve this.
As part of this, we apply diligent professional care and judgement in all our tax compliance activities, and providing sufficient evidence to support all judgements made.
Our approach to risk management and governance arrangements
For UK purposes the BPL Board of Directors has overall accountability in ensuring that tax is considered within the wider context of the business and in how tax risk is managed across the UK operations. Compliance and risk matters, including those concerning taxation as appropriate, are discussed at Board meetings. The Board typically meets three or four times a year.
The UK Financial Director is the Senior Accounting Officer for the Group and has responsibility for its approach to UK tax on a day-to-day basis and is supported by the wider group tax and finance function. Together, they are responsible for the identification, prioritisation and monitoring of tax risk across the UK business, as well as the escalation of tax risk to the core leadership, who in turn escalate to the BPL Board of Directors if necessary.
The Group will seek guidance from both internal and external tax advisors, particularly where the tax law is complex or uncertain. The Group acts in accordance with the advice provided and this ensures that the Group remains compliant with their UK tax obligations. The Group has appropriate tax accounting arrangements in place, including the people, policies, procedures and systems in place to identify, assess and manage tax risk.
Level of acceptable tax risk
The Group maintains a low threshold for risk in respect of UK taxation and we are committed to operating in a fair and ethical manner. This approach to tax risk is aligned to the approach taken for broader enterprise risks faced by the Group .
We are not prepared to accept a level of risk that could expose us to reputational harm and / or which could adversely affect our relationship with HMRC. Where there is significant uncertainty or complexity in relation to tax risk, we seek input from external advisors.
Our approach towards tax planning in relation to UK taxation
We have a low risk approach to tax planning as it affects UK taxation, and tax decisions are aligned to business and commercial strategy.
This approach ensures that we can create shareholder value whilst complying with applicable legislation requirements and HMRC guidance. The Group adopts a zero-tolerance approach towards tax evasion and the facilitation of tax evasion.
As a matter of policy, the Group seeks professional tax advice on each of their investment transactions in order to ensure compliance with all relevant UK tax laws and regulations.
Transparent and professional relationship with HMRC
The Group is committed to working with HMRC in an open, honest and transparent manner. Wherever possible, we seek to work collaboratively with HMRC in terms of keeping them up to date about any commercial developments and events in our business that may have a tax impact and work with HMRC to achieve early agreement on matters of complexity. The relevant group entities will make full disclosure to HMRC, based on legal grounds, where required.
The Tax Strategy has been approved by the BPL Board of directors on the 20th November 2023.
1 The UK entities related to the Kedrion Group include Sevenplatform VI Limited , Naga UK Topco Limited, Naga UK Bidco Limited, Bio Products Laboratory Holdings Limited and Bio Products Laboratory Limited.