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Steamship Mutual Underwriting Association Limited UK Tax Strategy

Published January 2024


This tax strategy is published to comply with the requirements of paragraph 22 Schedule 19 Finance Act 2016. It sets out how the Association approaches and manages its UK tax risk. This strategy has been reviewed by the Board of Directors and approved as meeting the tax and related governance requirements of HM Revenue and Customs (“HMRC”).

Approach to risk management and governance arrangements in relation to UK taxation

The Board has ultimate responsibility for setting its own level of tax risk – both management and compliance. Operational responsibility is delegated to the Chief Financial Officer.

As a mutual the Association is only assessed for corporation tax on its investment income. Insurance premium is an exempt supply for VAT purposes. This simplifies the risk management and governance requirements compared to most other companies. Nevertheless, the Association utilises the Manager’s finance professionals to ensure that its tax affairs are properly managed. Additional advice or guidance is sought from external tax advisors where appropriate.

The Association’s internal auditor conducts reviews of the Association’s taxation process from time-to-time with the last taking place in May 2023.  

Tax planning policy and acceptable level of risk in relation to UK tax

The Association has a low tolerance towards tax risk and wishes to be considered a low-risk business by HMRC. The Association does not undertake an aggressive interpretation of tax legislation or use artificial tax avoidance schemes. Wherever relevant the Association would also seek the opinion of external advisors to assess the tax impact of any transaction such as, for example, acquiring a lease on a property.  

Approach towards relationship with HMRC

The Association maintains a transparent and professional relationship with HMRC. The Association’s tax processes are designed to ensure required tax returns and payments are submitted on a timely basis, and any issues arising dealt with promptly and professionally. If any errors were identified HMRC would be notified at the earliest opportunity and steps taken to remedy the situation.