This document applies to all companies in the Pepper worldwide group, including Pepper’s Australian and UK companies.
Pepper’s operations incur a variety of business taxes in Australia, the UK and elsewhere. These include corporate income tax and corporation tax; GST, VAT and other indirect taxes; stamp duties; business rates; and employment taxes.
Strategic tax objectives
- Pepper’s tax strategy is to support its long-term business strategy by providing proactive, efficient, tax-optimised solutions for business decisions.
- Pepper seeks to manage all taxes to provide a competitive and responsible outcome in the interests of all stakeholders, those being:
- Business: Optimised opportunities for enhancing the company’s agility and flexibility to transact business;
- Shareholders: Secure a stable and attractive cash return with a higher profit after tax while assuming acceptable levels of tax risk; and
- Society: statutory obligations in relation to tax are satisfied with open, accurate and timely reporting along with payment of related taxes.
- Pepper is committed to acting responsibly in relation to its tax affairs, to fulfil compliance and disclosure obligations, and to operate in accordance with all relevant laws and regulations. Pepper recognises the importance of its economic contribution to society, of which tax forms a part, therefore it aims to ensure that it pays the right and proper amount of tax in each country in which the Group operates.
- Pepper seeks to be efficient with its tax affairs, and in this context, will ensure that all tax planning is built on sound commercial business activity.
- Pepper manages tax in line with the group governance framework and procedures, with uncertainties documented and reported on a regular basis.
- Pepper aims to build constructive relationships with tax authorities through encouraging the building of tax administration capability and the promotion of efficient tax systems.
To fulfil Pepper’s legal requirements and to support the above, this document sets out our approach to the following:
The commercial needs of Pepper are paramount, and all tax planning will be undertaken in this context. All transactions must therefore have a business purpose or commercial rationale.
Due consideration will be given to Pepper’s reputation, brand, corporate and social responsibilities when considering tax initiatives, as well as the applicable legal and fiduciary duties of directors and employees of Pepper and this will form part of the overall decision-making and risk assessment process.
Compliance with relevant legal disclosure requirements will be adopted and records will be maintained in order to be presented to tax authorities or other relevant bodies, as appropriate. Openness, honesty and transparency will be paramount in dealings with the tax authorities and other relevant bodies.
Tax risk management
Pepper seeks to manage tax risk through:
- Adopting strong technical positions
- Clear explanation of those positions
- Thorough documentation, particularly of facts, with assumptions only used where necessary
- Well established relationships with tax authorities
- Strong compliance procedures ensuring accurate and complete tax returns
Assessment of risk should take due account of:
- Both short and long term considerations and risks
- The impact on corporate reputation/brand
- The impact on relationships with governments
- The consequence of disagreements with tax authorities over the application of law
- The benefit of certainty in respect of uncertain or disputed tax positions.
Pepper’s appetite for risk is governed by the requirement that each tax position would, if challenged, be more likely to be settled in Pepper’s favour. We aim for certainty on tax positions we adopt, but where tax law is unclear or subject to interpretation, appropriate risk mitigation strategies will be implemented, such as obtaining written advice from tax professionals or seeking tax rulings from Revenue Authorities. Filing positions are subject to robust risk assessment and supported by full disclosure and sign-off at the appropriate level within Pepper.
Engagement with tax authorities
Pepper strives to have an open and honest relationship with tax authorities worldwide, including the ATO and HMRC, conducted in a spirit of co-operative compliance by targeting the following:
- We make our tax payments and file all necessary tax returns on or before the due dates and clearly disclose all relevant facts to tax authorities as required.
- We develop and foster good working relationships with tax authorities, government bodies and other related third parties.
- We undertake all dealings with tax authorities, government officials, ministers and other third parties in a professional, courteous and timely manner.