UK Asset Resolution Ltd (“UKAR”) is the holding company established on 1 October 2010 to bring together the government-owned businesses of Bradford and Bingley plc (“B&B”) & NRAM plc. On 5 May 2016, UKAR sold NRAM plc to affiliates of Cerberus Capital Management LP. Prior to the sale, assets and liabilities not included in the transaction were transferred from NRAM plc to a newly established subsidiary of UKAR now called NRAM Limited (“NRAM”). Both B&B and NRAM are in run-off and do not undertake any new business. UKAR is wholly owned by Her Majesty’s Treasury and operates in the UK only. This strategy applies to UKAR and the group of companies held by UKAR (“The Group”). A list of those companies to which it applies is set out below.
We are committed to meeting all statutory obligations in relation to UK taxation and to making full disclosure to the UK tax authorities.
Risk Management and Governance arrangements
Our risk management and governance processes are encompassed within a formal Group Tax Policy which is sponsored by the Finance Director and approved annually by the Board. We ensure that appropriate systems and controls are in place to enable the Group to meet its tax obligations. Under the Senior Accounting Officer regime, the Group provides an annual attestation confirming that it has the appropriate accounting arrangements in place to allow tax liabilities to be calculated correctly. Ultimate responsibility for tax risk resides with the Board. Governance processes ensure that suitably qualified people are involved in decisions related to tax.
Attitude towards tax planning
We will not engage in any tax planning that does not support a genuine commercial activity. We will not structure any transactions in a way that would have tax results that are inconsistent with the economic substance of the business activity being undertaken. If there is any uncertainty external advice will be sought as necessary to confirm the correct position.
We have no appetite for tax uncertainty and the level of tax risk is consistent with this objective. We seek to comply at all times with our regulatory obligations and see compliance with UK tax legislation as being key to managing tax risk.
Relationship with HMRC
We are committed to working positively, pro-actively and transparently with HMRC, through regular meetings and communication in respect of business developments, consistent with the Group’s low risk tax status. The relationship is based upon mutual trust and cooperative compliance. We endeavour to engage early with HMRC on a real time basis in any areas of uncertainty therefore minimising tax risk and providing greater certainty for both sides prior to the filing of tax returns. In July 2017 HMRC reconfirmed it’s assessment that UKAR has a “low risk” taxpayer status.
We consider that this statement complies with the Group’s obligations under paragraph 16 (2) of Schedule 19 Finance Act 2016.
This Tax Strategy applies to the financial year ending 31 March 2021.
Approved by the UKAR Board
2 March 2021
A list of The Group companies covered by this Tax Strategy is as follows:
- UKAR Limited
- Bradford & Bingley plc
- Mortgage Express
- Bradford & Bingley Investments
- Bradford & Bingley Homeloans Limited
- Leamington Mortgage Corporation Limited
- Bradford & Bingley Mortgage Management Limited
- F.M. Limited
- Mortgage Express (No.2)
- Scotlife Homeloans (No.2) Limited
- Silhouette Mortgages Limited
- Mortgage Express Holdings
- Finance for Mortgages Limited
- NRAM Limited
- NRAM (No. 2) Limited
- NRAM Homes Limited
- Northern Rock (Asset Management) Limited