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 & 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”).
On 29 October 2021, UKAR sold Bradford & Bingley Ltd (“B&B”) and NRAM together with their subsidiaries to affiliates of Davidson Kempner Capital Management LP. Following the sale, UKAR remains in government ownership and is responsible for meeting contractual obligations resulting from previous asset sales, sponsorship of the legacy B&B and NRAM pension schemes and administration of other non-loan assets and liabilities.
UKAR is wholly owned by Her Majesty’s Treasury and operates in the UK only. This strategy applies to UKAR only.
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 UKAR Tax Policy which is sponsored by and approved annually by the Board. We ensure that appropriate systems and controls are in place to enable UKAR to meet its tax obligations. Under the Senior Accounting Officer regime, UKAR 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 PwC who administer UKAR’s tax affairs, through meetings and communication in respect of business developments, consistent with UKAR’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 its assessment that UKAR has a “low risk” taxpayer status.
We consider that this statement complies with UKAR’s obligations under paragraph 16 (2) of Schedule 19 Finance Act 2016.
This Tax Strategy applies to the financial year ending 31 March 2022.
Approved by the UKAR Board
27 April 2022
A list of the companies covered by this Tax Strategy is as follows:
- UK Asset Resolution Limited