City & County Healthcare Group Tax Strategy

This document, approved by the Board of Directors of the City and County Healthcare Group (“C&C” or “Group”), sets out the Group’s approach to conducting its tax affairs and dealing with tax risks in accordance with paragraph 16, schedule 19 of the Finance Act 2016. It is effective for the year ended 31 March 2020 and will remain in effect until any amendments are approved by the Board.

The Group is the UK’s largest provider of community-based social care services delivering homecare, extra care and complex care through a network of 200 local branch offices.  Our portfolio of operating companies support thousands of people with a variety of care needs, delivered by a staff base of 14,000 care workers, to continue living independently at home.  At C&C our aim is to provide flexible, community-based care support of the highest standard that promotes independence, dignity and choice for our clients and customers.

There are four key tax areas which the Group is focused upon:

1. The Group’s approach to risk management and governance of its UK tax
2. The Group’s attitude towards tax planning
3. The level of risk that the Group is willing to accept in relation to UK tax
4. The Group’s approach to its dealings with HMRC
5. The Group’s approach to risk management and governance of its UK tax

The Board is accountable for the Group’s system of governance including ensuring that policies and procedures are in place to support the Group’s approach to taxation. The Group employs a well-resourced and experienced finance team, with clearly defined roles and responsibilities and distinct reporting lines to escalate any potential areas of risk.

The Group has a low tolerance for tax risk.  There is always the possibility of error which may result in incorrect application of tax rules, but the Group seeks to minimise this risk through regular consultation with the Group’s tax advisers and by adopting a risk averse position in the conduct of its affairs.

2. The Group’s attitude towards tax planning

The Board aims to ensure that the Group’s operations are conducted in a tax efficient manner, whilst remaining compliant with relevant legislation. The finance function provides appropriate input into operational decision making processes to ensure clear understanding of the tax consequences of any decisions made. Where required, third party advice is sought from the Group’s tax advisers to support Management’s decision making process.

3. The level of risk that the Group is willing to accept in relation to UK tax

A primary responsibility of the Group is to ensure compliance with all applicable tax laws and reporting and disclosure requirements applicable in the UK. The Group adopts a risk averse position in relation to regulatory risk and has robust controls and processes in place for providing the necessary information for reporting and disclosure to relevant stakeholders.

Where there is uncertainty regarding the application or interpretation of tax law, appropriate advice is sought from the Group’s independent advisers.

4. The Group’s approach to its dealings with HMRC

The Group takes its relationship with HMRC very seriously and seeks to maintain a responsible and responsive relationship with HMRC to ensure that the Group remains compliant with its taxation obligations. The Group is receptive to guidance and challenge from HMRC and is proactive in engaging with HMRC.