In accordance with Paragraph 16(2), Schedule 19, Finance Act 2016, Ford sets out below its group tax strategy for all UK companies within the Ford global group of companies, with the exception of FCE Bank plc, which will be publishing its tax strategy separately. This strategy applies from the date of publication until it is superseded.
Unless otherwise stated, references to ‘Ford’ or ‘the Group’ mean all UK companies within the Ford worldwide group (except FCE Bank plc).
Risk Management and Governance Arrangements
Tax policy ultimately resides with the global group’s Board of Directors. The Directors of each Ford legal entity also have a duty to ensure that risk is managed and that appropriate governance procedures are in place for their respective entities. To ensure that these duties are fulfilled a number of arrangements exist. These include:
· Taking decisions at an appropriate level, as governed by the global Ford group’s authorities in relation to tax matters.
· Regular reporting to the global group’s Board of Directors, Audit Committee and the Directors of UK legal entities.
· Quarterly formal certification procedures including the identification, evaluation, monitoring and reporting of tax issues and risks.
· Complying with internal control procedures and processes, which are subject to regular reviews, internal audits and self-assessment programs.
· Seeking and documenting external advice to support tax decisions.
· Implementing Ford’s core ethical behaviours and values.
Attitude of the group to tax planning (so far as affecting UK taxation)
Ford will not engage in tax planning other than that which is permitted by law and which supports genuine commercial aims. Where commercial activities and transactions may be structured in ways which have different outcomes for tax purposes, Ford may structure those actions in a way which legitimately provides the most advantageous outcome. In the event that there is any doubt as to whether the structure of the commercial actions and the tax results might be contrary to the intentions of Parliament or perceived to conflict with the spirit of the law then Ford will evaluate the actions through its internal tax governance arrangements and, where appropriate, discuss the matter with HMRC.
The level of risk in relation to UK taxation that the group is prepared to accept
Ford’s aim is to minimise the level of risk in relation to UK taxation at all times. The Group is not prepared to accept a level of risk that exposes it to reputational harm or which could adversely impact its relationship with HMRC. However, given the scale of Ford’s business and the complexity of tax legislation, it is inevitable that tax risks will arise. To ensure that the level of risk is kept as low as possible, a number of risk management policies and governance arrangements are in place, including controls specifically relating to tax that must be adhered to for all tax types.
The approach of the group towards its dealings with HMRC
Ford’s approach to dealing with HMRC is to maintain an open, professional and transparent relationship in relation to tax planning, compliance, strategy, risks and significant transactions. Ford commits to make full and accurate disclosures in tax returns and in correspondence with HMRC. The Group shall co-operate with HMRC at all times and deal with issues in a timely and collaborative manner.
Ford shall comply with its legal obligations and interpret legislation in a reasonable way that is aligned with the intentions of Parliament. Where genuine differences of opinion occur on the application of tax law, Ford will first seek to resolve these with HMRC through open dialogue and with reference to the relevant legislation and case law.
Criminal Finances Act 2017
Ford will ensure suitable policies and procedures are in place to prevent or minimize the risk of its employees, agents, suppliers or other third parties associated with Ford facilitating tax evasion as reflected in the Criminal Finances Act 2017. Ford will undertake, and periodically refresh, a risk-based assessment of its business activities to identify such risks and ensure procedures are adequate. Ford will communicate the policy and ensure adequate training is provided.
Date published: 29/01/2019