Background
Qatari Diar Real Estate
Investment Company (“QDREIC”) has a board approved tax strategy that governs
its approach to tax. This UK tax policy is a subset of the QDREIC Group (QDREIC
and all subsidiary entities collectively referred to as “the Group”) tax policy
and reflects the Group’s objectives with regards to UK tax.
QDREIC annually reviews its tax
strategy to ensure alignment with its overall business strategy. QDREIC is
committed to being a responsible taxpayer, acting fairly and transparently with
tax authorities.
Scope
QDREIC operates through a
number of entities in the UK (and also through non UK entities which hold UK
assets). These include limited companies, limited partnerships, unit trusts and
limited liability partnerships.
This tax strategy applies to
each entity that has any UK tax obligation. Tax for the purposes of this
strategy are those taxes and duties set out in paragraph 15(1) of Schedule 19
Finance Act 2016. This tax strategy relates to the financial year ended 31
December 2020. QDREIC regards the publishing of this document and making it
available on its website as fulfilling the Group’s obligations under Schedule
19 Finance Act 2016.
Although joint venture operations
in the UK are not covered by this tax strategy, whilst working with joint
venture partners, QDREIC applies, to the extent possible, the same principles
in its approach to those business operations that it would to a wholly owned
business operation.
The Group intends to review
this tax strategy annually.
The Group’s Tax Objectives for the UK
The objectives of the QDREIC UK
tax strategy are to:
·
Ensure that the Group is compliant with all UK filing and tax payment
obligations.
·
Ensure full disclosure to HMRC of all relevant facts and information.
UK Tax Strategy
The Group’s approach to Tax
Risk Management
QDREIC has a full suite of
documented policies, procedures and reporting requirements for all of its
business activities, which include all aspects of tax risk management. In
applying the tax risk management policy, tax risks are identified and reported
to management regularly. In order to identify, manage and mitigate tax risk:
·
The Group employs tax professionals to assist the UK business in its
filing and payment obligations and to provide advice to the UK business.
·
Where considered necessary external professional tax advice is taken to
supplement the in-house capability.
·
UK tax risks are collated as part of the overall QDREIC Risk Management
Framework on a regular basis that identifies material or significant risk
areas.
·
UK management will receive a six monthly update on tax risks as part of
the risk management framework.
·
The Group has a desire for low tax risk.
Where relevant Tax is always
considered as part of the commercial business decision making process:
·
Commercial business decisions receive tax overview as a matter of
course.
·
The Group carefully considers the tax impact of all major business
decisions.
·
No tax planning which results in tax benefits inconsistent with the
underlying commercial business substance would be entered into unless there is
specific legislation designed to promote that result.
·
The Group may undertake tried and tested planning which is common in
the market and results in a low level of tax risk relating to a commercial
transaction if, after taking relevant professional advice, it is considered
appropriate.
·
Where relevant external professional advice would be sought depending
on the tax risk analysis, taking into account the nature of the tax risk and
the commercial profile of the transaction or risk.
In dealings with HMRC, the
Group:
·
Aims to have a constructive relationship with HMRC, based on regular
and proactive communication.
·
Aims to engage in open discussion about contentious issues with HMRC.
·
Where appropriate will obtain tax clearances from HMRC.
·
Will ensure that it is advised by an appropriate professional firm
where there is a difference of interpretation between the Group and HMRC on the
application of specific legislation prior to any formal appeal proceedings.
Tax administration and payment:
·
The Group has low tolerance in tax risk for errors, omissions or late
submission of tax filings.
·
Tax returns should contain all relevant information necessary for HMRC
to be able to consider the transactions reported.
·
Tax returns should contain accurate calculations of the tax due.
·
Where tax payments are based on estimated or budgeted figures the
latest estimate or budget available is used, reflecting the best estimation of
current circumstances.
·
Should an inadvertent error occur it would be fully disclosed to HMRC
in a timely manner.
·
QDREIC employs a tax process tracking and filing system to ensure that
all reporting requirements are captured and delivered in line with HMRC
deadlines.