Publication date: 7 December 2021
Introduction to Rubix Group Structure
This strategy applies to Rubix Limited (formerly Rubix Group Holdings Ltd) and to the group of UK companies headed by Rubix Limited in accordance with paragraph 19 of Schedule 19 to the Finance Act 2016 (‘Schedule’). A list of the entities to which it applies is set out below. In this strategy, references to ‘Rubix Limited’ or ‘the Group’, are to all these entities. The strategy is being published in accordance with paragraphs 19(2) and 19(4) of the Schedule.
This strategy applies from the date of publication until it is superseded. References to ‘UK Taxation’ are to the taxes and duties set out in paragraph 15(1) of the Schedule which include Income Tax, Corporation Tax, PAYE, NIC, VAT, Insurance Premium Tax, and Stamp Duty Land Tax. References to ‘tax’, ‘taxes’ or ‘taxation’ are to UK taxation and to all corresponding worldwide taxes and similar duties in respect of which the Group has legal responsibilities.
The group reviews as standard the impact of changes in tax legislation and administration. This has recently included Making Tax Digital, DAC 6 obligations and the impact of IR35 rule changes.
During the course of 2020 and 2021, the group made a number of UK acquisitions as detailed in the list of entities at the end of the tax statement, as well as continuing to expand into Europe through further European acquisitions.
Rubix is committed to full compliance with all statutory obligations and full disclosure to relevant tax authorities. The Group’s tax affairs are managed in a way which takes into account the Group’s wider corporate reputation in line with Rubix’s overall high standards of governance.
Rubix’s Tax Governance Document, which has been formally adopted by the Board is a written codification, for internal use, of Rubix’s policy for the management of taxes and attitude to risk and tax planning.
As well as detailing the responsibilities and principles and approach to taxes management, the “governance objective is to comply with all its legal requirements across the various taxes, in a manner and spirit that ensures we pay the right and responsible amount of tax. Rubix adopts a low risk approach when considering tax planning and does not enter into aggressive tax planning measures.”
Governance in relation to UK taxation
Ultimate responsibility for Rubix Limited’s tax strategy and compliance rests with the Board of Rubix Limited.
Executive management of the tax affairs of the Group is delegated by the Board to the Chief Financial Officer (‘CFO’).
The CFO is the Board member with executive responsibility for tax matters.
Day-to-day management of Rubix Limited’s tax affairs is delegated to the Head of Tax who reports to the CFO.
The Head of Tax is a fully qualified member of the Chartered Institute of Tax.
The Board ensures that Rubix’s tax strategy is one of the factors considered in significant business decisions and transactions undertaken.
The Head of Tax reports to the Board and Audit and Risk Committee on Rubix’s tax affairs and risks during the year, as well as on relevant tax issues arising from transactions entered into and from changes in legislation and changes to business operations.
The Group Internal Auditor’s requirement to monitor the integrity of Rubix’s financial reporting system, internal controls and risk management framework includes those elements relating to taxation.
Rubix operates a system of tax risk assessment and controls as a component of the overall internal control framework applicable to the Group’s financial reporting system as well as to ensure compliance with the Senior Accounting Officer framework.
Rubix seeks to reduce the level of tax risk arising from its operations as far as is reasonably practicable by ensuring that reasonable care is applied in relation to all processes which could materially affect its compliance with its tax obligations.
Processes relating to different taxes are allocated to appropriate process owners, who mitigate key risks through the operation of appropriate controls and sign-off procedures. Key risks are monitored for business and legislative changes which may impact them and changes to processes or controls are made when required.
Transactions which may have significant tax implications are reviewed and advised upon by the Head of Tax. Advice is sought from external advisers where appropriate on areas of a complex, risky or specialist nature or where in the judgement of the Head of Tax, additional advice ought to be sought. Continued compliance is ensured through appropriate training and literature as well as regular liaison with tax advisors and with HMRC.
Attitude towards tax planning and level of risk
Rubix Limited adopts a non-aggressive approach to tax planning and tax compliance.
Rubix Limited manages risks to ensure compliance with legal requirements in a manner which ensures payment of the right amount of tax.
When entering into commercial transactions, Rubix seeks to take advantage of available tax incentives, reliefs and exemptions in line with, and in the spirit of, tax legislation.
Rubix does not undertake tax planning unrelated to commercial transactions, other than to ensure continued compliance (such as updating Transfer Pricing policies), nor enter into aggressive tax planning measures.
The level of risk which Rubix accepts in relation to UK taxation is consistent with its overall objective of achieving certainty in the group’s tax affairs. At all times Rubix seeks to comply fully with its regulatory and other obligations and to act in a way which upholds its reputation as a responsible company. In relation to any specific issue or transaction, the Board is ultimately responsible for identifying the risks, including tax risks, which need to be addressed and for determining what actions should be taken to manage those risks, having regard to the materiality of the amounts and obligations in question.
Relationship with HMRC
Rubix seeks to have a transparent and constructive relationship with HMRC through regular annual meetings and ongoing communication with the Group’s dedicated Customer Compliance Manager (‘CCM’) and HMRC specialists. Through these CCM meetings and in the course of ongoing conversations, developments in Rubix’s business and current, future and retrospective tax risks and interpretation of the law in relation to all relevant taxes are discussed.
This ongoing relationship is also helpful in expediting tax claims and elections and seeking clarification on processes and advance clearances.
Accordingly, Rubix ensures that HMRC is kept aware of significant transactions and changes in the business and seeks to discuss any tax issues arising at an early stage. When submitting tax computations and returns to HMRC, Rubix discloses all relevant facts and identifies any transactions or issues where it considers that there is potential for the tax treatment to be uncertain.
We liaise with HMRC on a regular basis and maintain an open and honest relationship with them and receive the same treatment in return. This approach facilitates full compliance and helps resolve any potential difficulties quickly and efficiently.
List of entities covered by this tax strategy
- Rubix Group International Limited
- Brammer UK Limited
- Rubix Group Midco 4 Limited
- Rubix International Limited
- Brammer Vending Limited
- Rubix Limited
- Rubix Group Midco Limited
- Rubix Group Midco 2 Limited
- Rubix Group Midco 3 Limited
- Rubix Group Finco Limited
- Rubix Group Bufferco Limited
- Brammer Holdings No.3 Limited
- Matrix Tooling Services Limited
- Peter Campbell (Sales) Limited
- Rubix Europe Limited
- Hydra Engineering Services Limited
- Matara (UK) Limited
- Compcare Compressed Air Limited (acquired June 2021)
- The Deritend Group Limited (acquired September 2021)
- TDGL 2 Limited (dormant) (acquired September 2021)
- RMB Engineering Services Limited (dormant) (acquired September 2021)
- Rubix UK Ltd (dormant)
- Rubix Group UK Ltd (dormant)
- Rubix 1234 plc (dormant)