UK Tax Strategy

Introduction

Finance Act 2016 introduced legislation which requires groups of a certain size to publish their tax strategy, or parts of their strategy, which are relevant to UK taxation. This document sets out the UK companyʼs tax strategy in accordance with Paragraph 16(2), Schedule 19, Finance Act 2016. The published tax strategy covers the following areas (all in relation to UK taxation): 

  • Approach to risk management and governance arrangements.
  • Attitude towards tax planning.
  • Level of risk tolerated.
  • Approach towards dealing with HM Revenue and Customs ('HMRC').

The purpose of this document is to set out the UK companyʼs policy and approach to UK taxation and applies to the accounting year ending 31 December 2020. The tax strategy has been approved by the Board of Trico Group Holdings LLC who will continue to monitor the tax risks faced by the company. The tax strategy will be reviewed annually and any amendments approved by the Board. 

Trico Limited is a UK subsidiary of Trico Group Holdings LLC, a company incorporated in the US.  The global Trico Group (the ʻGroupʼ) is a market leader in the manufacturing of windshield wiper blades & systems. The Group has a global presence with operating facilities in the UK, USA, Argentina, Mexico Australia and China. At present UK operations are relatively small, (Annual Turnover of approximately £16m), compared to the wider global group, however, it is anticipated that the Groupʼs presence in the UK and Europe will expand as a result of future acquisitions. Based on current operations, the UK faces a low level of tax risk, however the situation will be monitored closely going forwards.

The Groupʼs business activities are subject to a variety of taxes around the world. Specifically in the UK, Tricoʼs activities are subject to various taxes, including corporate tax, employment tax (payable in the capacity of employer) and property taxes. Indirect taxes and employeesʼ taxes (deductible from employeesʼ earnings) are also collected and paid.  

As part of the Groupʼs corporate objective, we are committed to creating long-term value through the responsible, sustainable and efficient delivery of our key business objectives. We therefore adopt an approach to tax that supports this strategy and balances the interests of our key stakeholders – employees, suppliers, customers and the wider community. We aim to pursue a tax strategy that is aligned with the Group's overall business strategy. claim relating to this Site, and the use of this Site and the materials contained herein is governed by the laws of the European Union, without regard to conflict of law principles. You also agree and hereby submit to the exclusive personal jurisdiction and venue of the European Union, with respect to such matters.

Approach to risk management and governance arrangements

The UK's tax affairs are managed by the UK Finance Director with support from the local UK finance team, who are responsible for the day-to-day financial operations of Trico Limited, including tax and treasury management. 

The Groupʼs Board has minimal active involvement in the UK tax affairs of Trico Limited. Occasionally, guidance is sent out by the Board, but in practice, due to the size of the UK operations, there is very little intervention from the parent company.  Trico Limited operates a system of tax risk assessment and controls as a component of the companyʼs overall ongoing internal control framework and key risks are periodically monitored with changes to processes or controls being made when required.

The UK company faces a low level of inherent risk due to its small size and extent of the UK operations in comparison to the wider Group. Due to the Groupʼs international presence and growth strategy, the risks facing the UK company may increase therefore our approach to tax risk will be monitored closely.  The company seeks to reduce the level of tax risk arising from its actions as far as is reasonably practicable. We aim to continuously monitor our internal controls and implement an appropriate level of diligence and care in relation to all processes which could materially affect its compliance with its UK tax obligations. 

As an ongoing part of our risk management, we ensure that the finance team hold the appropriate existing technical expertise and engage in continuing professional development. The finance team is supported by external advisers when there is a perceived need for specialist guidance in respect of potentially complex or uncertain tax matters. Trico Limitedʼs tax compliance obligations are performed by external advisers who are also responsible for preparing and filing the relevant tax filings. VAT returns and PAYE submissions remain the responsibility of the UK finance team.

Whilst the UK company currently faces a low amount of tax risk, should a tax risk be identified the UK finance team would aim to resolve this internally in the first instance. External advisers are engaged where technical expertise is required for complex matters. Where a tax risk is identified that could not be resolved by the UK team, it would be escalated to the Group for consideration. The Groupʼs Board, would ultimately have the final decision in any matter that had tax implications for the Group as a whole, but in any event would ensure that their decision did not result in any breach of local regulations or legislation. 

Attitude to tax plannng

As a Group we maintain a risk averse attitude and only those transactions with real economic substance and sustainable business purpose are executed. Guidance is sought from senior management regarding particularly complex or high risk tax matters and, if significant, approval and sign off from the Groupʼs Board is sought.

The company has a low appetite for risk in respect of taxation and seeks to minimise the risk of uncertainty or disputes. Trico Limited aims to comply with all relevant national laws, regulations and reporting requirements in the UK. The company will seek to use tax efficient incentives and reliefs where appropriate, however, it is not our policy to enter into any aggressive or abusive tax planning. Guidance is sought from external tax advisers regarding those acceptable tax savings and benefits that are available to the company. 

Level of tax risk 

The company undertakes very little tax planning, and therefore the UK is deemed to have low level of tax risk.  The company applies reasonable care to all processes which could materially affect its compliance with its tax obligations. The Group engages third party tax advisors to help manage these risks, when deemed to be significant or complex, and to carry out the companyʼs compliance obligations in the UK.  

Stakeholders expect the activities of the company to be carried out in accordance with national laws, including tax law, and do not exert any influence over the tax risks of the business. 

Approach to dealing with HMRC

Based on the size of the UK operations, Trico Limited has limited interaction with HMRC, however, we are committed to fostering a constructive and transparent relationship with the UK tax authorities. 

Trico Limited acts in accordance with all relevant laws and disclosure requirements as necessary to ensure compliance with the UK tax law.