Regulatory 2

Our commitment

The ClearBank Group is committed to complying with applicable tax laws, regulations, statutory obligations and full disclosure to the tax authorities in respect of taxation matters. ClearBank recognises how taxation plays a key role in the economy and contributes towards the sustainable development of society. The statements below comply with the requirements to publish a tax strategy for the year ended 31 December 2023, under paragraph 16(2) Schedule 19 Finance Act 2016.

Managing Tax Risks

The Board of Directors of each ClearBank Group company hold ultimate responsibility for ensuring the effective management of tax related risks, overseeing risk management practices and fostering a risk-aware culture coupled with thoughtful risk-taking. In addition, the Group Board is ultimately responsible for setting Group tax strategy.

Executive responsibility for tax matters lies with the Group Chief Financial Officer, while responsibility for day-to-day matters is delegated to the Group Head of Financial Control, Head of Tax and Financial Control teams. Individuals with responsibilities over the ClearBank Group’s tax affairs are equipped with appropriate knowledge, skills, qualifications and capabilities, and where required, are assisted by external advisors.

The Risk Management function performs a second line role, providing independent and objective challenge to the business in the effective operation of the risk management system.

Risk Management Approach

Tax risk is managed in a similar way to any other area of financial or operational risk through management procedures that have been put in place. Adherence to risk management protocols together with an associated governance structure ensures an effective process to identify and manage risks.

ClearBank aims to control tax risks to ensure that material losses do not arise and actively seeks to identify, monitor, mitigate and manage tax risks through risk assessment procedures and controls as part of the group-wide Enterprise Risk Management Framework (ERMF). The ClearBank Group’s risk management approach and ERMF are supported by the 3 Lines model which also includes the financial reporting and tax risk in the taxonomy.

Through this approach, process owners review activities and processes to identify risks (including tax risks) and to implement and maintain mitigating controls as well as monitor them for business and/or legislative changes which could impact them. Advice is sought from reputable external advisers where appropriate.

Attitude towards Tax Planning

The ClearBank Group adopts a conservative approach to tax planning, which is based on prudent interpretation of tax legislation and aligned to the substance of the economic and commercial activity of the business. A key tax principle of the ClearBank Group is to only undertake tax planning and transactions that are underpinned by genuine commercial drivers and economic factors. As a business, ClearBank seeks to benefit from available tax incentives (such as Research & Development Expenditure Credits), reliefs and exemptions in line with, and in the spirit of the tax legislation, all the while cognisant of its obligations to its communities and wider society.

Working with Tax Authorities

ClearBank seeks to have a transparent and constructive relationship with HMRC, and other tax authorities, working openly and professionally to resolve any tax matters through proactive discussion. Any information requests from tax authorities are dealt with efficiently in a timely manner and the bank endeavours to resolve any inquiries as soon as practicable. ClearBank demands integrity, transparency and competence from its staff and external advisors in all dealings with the tax authorities.