Inigo Group Tax Strategy

1.Introduction

    Inigo Group (“the Group” or “Inigo”) provides specialty insurance and reinsurance coverage, transacted at Lloyd’s of London. The publication of this tax strategy (“the Group Tax Strategy”) by Inigo Limited, the ultimate parent of the Group, fulfils obligations prescribed by paragraph 16(2) of Schedule 19 of the Finance Act 2016 enacted in the United Kingdom which requires Inigo Limited to publish the tax strategy on behalf of all its group of companies.

    The Group is domiciled in the UK and operates via several different legal entities.

    The Group Board of Directors have approved this Tax Strategy. We will perform periodic reviews of the tax strategy to assess the appropriateness of the strategy and to ensure tax risk controls and monitoring activities are conducted as documented.

    The Group is committed to transparency in its tax affairs, which includes publishing its tax strategy and providing stakeholders with clear and accurate information about its tax practices where required.

    2. Approach of the Group to risk management and governance arrangements in relation to UK taxation

    Responsibility for the Group’s tax strategy ultimately rests with the Group Board of Directors, supported by the Group Audit Committee in reviewing and monitoring material tax issues and judgements. The Internal Audit function provides an independent review of the risk management process. The Group Risk Committee is responsible for ensuring that the financial and non-financial risks are being effectively mitigated. Day-to-day responsibility tax risk management, governance and managing the tax affairs of Inigo group of companies is delegated to the Group Chief Financial Officer (“Group CFO”).

    The management of tax risk focuses on:

    • Commitment to comply with all applicable laws and regulations.
    • Timely filing of tax returns.
    • Timely settlement of tax dues.
    • Timely identification and reporting of any significant tax issues, including tax uncertainties and associated risks, to the relevant Boards and Audit Committees were deemed appropriate.
    • Compliance of intercompany transactions with arm’s length principles as defined by the OECD transfer pricing standards and relevant local law.
    • Consistency of tax risk management with the Group’s wider governance, risk and control framework.
    • Adequate training to key staff to help identify new tax obligations.
    • Maintenance of internal control frameworks and appropriate accounting arrangements which comply with the UK’s Senior Accounting Officer (“SAO”) legislation. Periodic reviews are performed to ensure compliance with the SAO control framework.

    3. Attitude of the Group towards tax planning

    Inigo recognises that careful tax planning is critical for our business success. The Group’s tax planning blends business acumen and knowledge from our external tax advisors to focus on consistency, compliance and the Group’s strategic objectives.

    We have continued to build our people and systems to achieve the highest standards of compliance to meet the Group’s obligations under tax legislation.

    We consider, among other factors, the tax laws of the countries in which we operate and endeavour to pay all taxes due in the right place at the right time. Whilst the Group strives to be efficient with its tax affairs, tax mitigation is not a driver for activity.

    Tax planning opportunities arising from significant commercial transactions will be considered by the Board and must be supported by an appropriate level of tax analysis.

    4. The Level of Risk in relation to UK taxation that the Group is prepared to accept.

    The Group has low tolerance to tax risk. Where tax risks do arise, the Group actively seek to identify, evaluate, monitor and manage this risk, in line with our risk management framework to ensure they remain within our risk appetite.

    We would seek advice from our external tax advisors where appropriate on any tax obligations and in order to achieve compliance with, new laws or changes to existing laws.

    Any significant tax risks or issues identified are escalated to the Group Risk Committee (RIC) and, if necessary, to the Board of Directors for review and guidance, ensuring alignment with the Group’s Enterprise Risk Management Framework.

    5. The Approach of the Group towards its dealing with HMRC

    We seek to maintain a positive and transparent relationship with all our regulators including HMRC, as a key element in conducting our business effectively.

    In a spirit of cooperative compliance, Inigo is committed to:

    • Ensure all interactions with HMRC are conducted in real time in an open, collaborative, and professional manner.
    • Respond promptly to any enquiries that are raised by tax authorities.
    • Request advance clearance from HMRC on major events and complex areas of tax law.