This tax strategy document sets out the policy and approach in respect of how the UK operations of the Fidelis Insurance Holdings Limited (“FIHL”) Group conducts their UK tax affairs and manages tax risk for the year ended 31st December 2019. FIHL is a privately owned Bermuda-based holding company, which, through its subsidiaries in the United Kingdom, Republic of Ireland and Bermuda, is a global provider of specialty insurance and reinsurance products. The Group operates in the UK via several different legal entities.¹
Fidelis manages its tax affairs based on the following principles:
- Compliance with all relevant tax laws, regulations and disclosure obligations;
- Paying the right amount of tax, in the right place, at the right time.
- Ensuring compliance with the arm’s length principles as defined by OECD transfer pricing standards and relevant local legislative requirements.
- Arranging its commercial affairs in a tax efficient manner and only engaging in tax planning that supports genuine commercial activity; and
- Maintaining an open, professional, and transparent relationship with HM Revenue & Customs (“HMRC”).
Our approach to tax risk and governance
The Boards of each of the UK entities are responsible for overseeing the businesses tax strategy, policy and affairs and are supported by the Group Audit Committee in reviewing and monitoring material tax issues and judgements. Day to day responsibility for managing the tax affairs of the UK entities is delegated to the UK Chief Financial Officer (“UK CFO”). The UK CFO establishes appropriate policies and procedures which seek to manage tax risks whilst ensuring consistency with the Group’s wider governance, risk and control framework. The UK CFO also ensures the timely identification and reporting on any significant tax issues, including tax uncertainties and associated risks, to the relevant Boards and Audit Committees where deemed appropriate.
Our attitude to tax planning
In structuring our commercial activities, we will consider, amongst other things the tax laws of the countries that we operate in, with a view to maximising value on a sustainable basis for our stakeholders. Any tax planning we enter into will support genuine commercial activity and we will not undertake any tax planning that is contrived or artificial, based solely on tax merits, or that is inconsistent with legislative intent. In planning our tax affairs we may take advantage of and claim valid reliefs and incentives where available. Where there is particular uncertainty or complexity in relation to a tax position we will seek external advice.
The level of tax risk that we are willing to accept
We have a low tax risk appetite and will plan at all times to adopt tax positions that are supported by both the letter and spirit of applicable tax laws and regulations. Where tax risks do arise we actively seek to identify, evaluate, monitor and manage these risks, in line with our tax governance arrangements to ensure they remain within our risk appetite.
Approach to dealing with tax authorities
We are committed to the principles of transparency and honesty in our approach to dealing with HMRC. We commit to:
- Make fair, accurate and timely disclosures and respond to queries and information requests in a timely fashion.
- Seek to resolve issues with HMRC to resolve issues by agreement where possible.
- Ensure all interactions with HMRC are conducted in an open, collaborative and professional manner.
This document is considered to comply with the requirements of Paragraph 19 (2) Schedule 19 of the Finance Act 2016.
¹ The FIHL Group operates in the UK via the following legal entities which are all covered by this tax strategy – Fidelis Underwriting Limited, Fidelis Marketing Limited, Fidelis European Holdings Limited, Pine Walk Capital Limited, Radius Specialty Limited, Oakside Surety Limited, Aware Specialty Limited, Kersey Specialty Limited and Perigon Product Recall Limited.