Tax strategy

ClearBank, and all companies within the group, are 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 for each UK tax resident company to publish a tax strategy for the year ended 31 December 2025, under paragraph 16(2) Schedule 19 Finance Act 2016.

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

The Group 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.

ClearBank has a very low appetite for tax risk which 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). ClearBank’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.

ClearBank has no appetite for tax structures designed to evade tax and 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 ClearBank 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.

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 group 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.