This Tax Strategy is applicable to the business activities of Osborne Clarke LLP and all UK affiliated entities.
This document sets out the UK Tax strategy employed by Osborne Clarke LLP and is published in accordance with the Finance Act 2016, Schedule 19, para. 16.
The Tax Strategy is reviewed periodically to ensure its accuracy and has been approved by the Firm's Executive Board who have responsibility for monitoring its application. It is effective for the accounting period ended 30 April 2024 and subsequent financial periods until it is superseded.
1. Compliance and Reporting
Osborne Clarke LLP is committed to fulfilling its statutory obligations to pay all taxes required by laws and regulations in the UK and each of the jurisdictions in which it operates. That means paying the right amount of tax in the right place at the right time.
We take appropriate professional advice, apply diligent professional care and judgment in making decisions relating to the tax treatment of business activities and tax compliance. Sufficient evidence is maintained to support all judgments made.
2. Governance and Risk Management
2.1 Governance
Accountability for Osborne Clarke's UK tax operations lies with the Firm's Executive Board. This includes providing guidance and oversight over how tax risk is managed across Osborne Clarke. Day-to-day responsibility and management of Osborne Clarke's tax operations is delegated to the Head of Financial Control and Partnership matters, who is supported by a team of appropriately qualified individuals who work alongside our external tax advisers to meet the firm's reporting, filing and payment obligations accurately and on a timely basis. The Head of Financial Control and Partnership matters reports to the Firm's Chief Finance Officer (CFO) who forms part of the Firm's Executive and sits on its Executive Board.
As part of this governance framework, there are procedures as to how tax risk is managed and escalated where necessary to the Firm's Executive Board and Partnership Council. We provide our members with an internal tax withholding to ensure sufficient funds are available to meet their obligations as they relate to Osborne Clarke's matters.
2.2 Risk Management
Osborne Clarke proactively seeks to identify, evaluate, manage, and monitor tax risk and uncertainty. Where matters are significant or higher risk, whether because of the value or because an element of judgment is required, or where there could be a potential adverse financial or reputational outcome, these are considered by the Firm's Executive Board. If there is significant uncertainty or complexity in relation to tax risk, we seek input from external advisers and, where possible, seek clarity from HMRC.
The CFO is also responsible for ensuring that tax risk policies and procedures are adhered to across the business. In this regard, Osborne Clarke has a system of internal controls over tax compliance processes that include segregation of duties, initial and second levels of review and, where appropriate, reconciliation checks to underlying systems to provide additional controls over the accuracy of the tax figures used.
3. Tax Planning
In delivering our business objectives, we take account of tax laws in every territory in which we operate. However, Osborne Clarke seeks to create value for our partners and as a result we may respond to tax incentives and reliefs, where appropriate, in a way that is consistent with HMRC and government policy and the commercial objectives of the business. We will not seek to engage in any transactions that are artificial or contrived.
As appropriate, Osborne Clarke will seek external professional tax advice to ensure that any such incentives and reliefs are applied legitimately, particularly if the outcome of a transaction (or its tax treatment) is uncertain or complex.
4. Our Dealings with HMRC
Osborne Clarke seeks to maintain an open and transparent relationship with HMRC. Wherever possible, and where interpretation is uncertain, we will seek to achieve early agreement on issues to gain certainty and, should any differences of opinion arise regarding the interpretation of the law, we will seek to resolve these by working, where possible, collaboratively with HMRC.
Published: 1 March 2024
