NBA UK Ltd (NBA UK) is a subsidiary of NBA Properties, Inc. (NBAP). It provides marketing support services for NBAP operations outside the US, primarily in Europe, the Middle East and Africa. NBA UK considers this publication to fulfill its duty under the UK Finance Act 2016 to publish its UK tax strategy for its fiscal year ended September 30, 2018. The tax strategy has been prepared in accordance with the requirements detailed at paragraph 19(2) Schedule 19 Finance act 2016.
Approach to Risk Management & Governance:
NBA UK manages tax risk through a combination of people, processes, controls and systems.
- Overall responsibility for UK tax compliance and governance rests with the finance department of the parent entity in the US.
- NBAP engages an internal audit function to ensure that company policies and controls are applied within the company and its subsidiaries as intended. The operations of the company and its subsidiaries are subject to external audit annually.
- NBA UK engages third party advisors to prepare its UK tax returns; NBAP’s tax staff reviews the returns, and NBAP’s auditors review the financial accounting for NBA UK’s tax compliance.
- NBAP monitors for relevant changes in UK tax law with the assistance of its external tax return preparers and advisors.
- Any material proposed changes in the tax structure of either NBAP or NBA UK cannot be implemented without approval from NBAP internal tax as well as NBAP’s legal department, internal audit department and auditors.
Tax Planning & Level of Risk Acceptable to Co.
NBA UK does not and will not engage in tax planning that is not compliant with the law and which does not have commercial substance. All related party transactions are conducted on an arm’s length basis, as is required by current OECD principles. NBA UK does not and will not pursue risky tax positions that may violate the intent of UK tax law. When interpreting the UK Tax laws, we will be guided by HMRC guidance notes/manuals and/or external advisors, to ensure that the relevant law is interpreted as intended. If such guidance or advice does not reduce uncertainty to a low level for any issue that might have a material tax impact for NBA UK, it is the policy of NBAP and NBA UK to approach the relevant tax authority for more guidance.
Company’s approach towards its dealings with HMRC
The company’s goal is to work with HMRC in a cooperative and transparent manner. NBA UK commits to make full, timely and accurate disclosures of relevant information in its returns and correspondence with HMRC. Where genuine differences arise as to the appropriate application of UK tax law, NBA UK commits to first seek to resolve such differences through open dialogue, with reference to the supporting legislation and official guidance.