Tax Strategy

Luxfab Ltd
Tax Strategy for year ending 31st August 2018
Published August 2018


Contents

1. Overview
2. Tax Risk Management
3. Tax Planning: Our Approach
4. Tax Risks
5. Relationship with Tax Authorities

 

1. Overview


Luxfab Ltd is a holding company for the trading entity of Holophane Europe Ltd (together, the ‘Companies’), for whom the day to day management and implementation of tax affairs is provided by the local finance team. Compliance matters are dealt with both in-house and through outsourced professional service firms to ensure accuracy.
This document, approved by the Directors of Luxfab Ltd, sets out the Companies’ policy and approach to conducting its tax affairs and dealing with tax risk, effective for the year ending 31st August 2018.
The Companies are committed to complying with all relevant tax laws, rules, regulations, reporting and disclosure requirements, and to having a constructive, professional and transparent relationship with all relevant tax authorities, based on the concepts of integrity, collaboration and trust.
Luxfab Ltd is part of Acuity Brands Inc, the ultimate controlling party.
 


2. Tax Risk Management


The Companies follow risk management systems as part of the internal control processes, identifying, assessing and managing risks by applying diligent professional care and judgement in order to arrive at well-reasoned conclusions, and where necessary, taking external advice to help inform the Companies’ decision making. As part of Acuity Brands Inc, the Companies follow strict Sarbanes Oxley processes.
In reviewing the risks of a tax action or decision, appropriate consideration is given to:
 
  • The legal and fiduciary duties of directors and employees.
  • The requirements of any related internal policies or procedures.
  • The maintenance of the Companies’ corporate reputation, having particular regard to the way we interact with the communities around us.
  • The tax benefits and impact on the Companies’ reported results compared to the potential financial costs involved, including the risk of penalties and interest.
  • The wider consequences of potential disagreement with tax authorities, and any possible impact on relationships with them.
  • The Companies have clearly defined lines of responsibility for their tax affairs, with decisions being taken in line with Group policy, ensuring they are taken at the appropriate level.
 


3. Tax Planning: Our Approach


The Companies do not seek to take overly aggressive tax positions and seek to adhere to relevant tax laws whilst seeking to minimise the risk of uncertainty or dispute
The Companies will use available incentives and reliefs to minimise the tax costs of conducting its business activities in full compliance with UK tax laws and transfer pricing regulations where these support the commercial needs of the business, but will not use them for purposes which are knowingly contradictory to the intent of the legislation.
All transactions between the Companies and other Acuity Brands Inc companies are conducted on an arm’s length basis and in accordance with acceptable international tax norms based on input from qualified professional advisors. The Companies are subject to the Country by Country reporting obligations and the master file filings are to be made by Acuity Brands Inc, the ultimate parent company.
 


4. Tax Risks


The Companies have a low appetite for tax risks, but recognises the key risks:
Compliance and Reporting Risk is actively managed by ensuring internal staff are equipped with the essential knowledge and skills to carry out relevant work, and by obtaining external assistance from professional firms.
Changes in Tax Legislation and other regulations are taken seriously by the Companies, and as such are proactively evaluated as part of an ongoing relationship with professional experts.
Transfer Pricing is under periodic review to ensure ongoing compliance to acceptable international tax norms.
Reputational Risk is considered as part of any decision making process, and if doubt exists a prudent approach is taken.
 


5. Relationship with Tax Authorities


The Companies are committed to the principles of openness and transparency in their dealings with tax authorities.
In particular, the Companies endeavour to:
 
  • Interpret the law in a reasonable way.
  • Maintain an open and collaborative professional relationship at all times with HMRC.
  • Where appropriate, engage in meaningful dialogue with HMRC on relevant taxation matters.
  • Make fair, accurate and timely disclosures in correspondence and returns, respond to queries and information requests in a timely manner and work with HMRC to mutually resolve issues wherever possible.
  • Strive for early agreement in the event of a dispute and achieve certainty wherever possible.