Fisher Investments Europe Limited (FIE) is authorized and regulated by the UK Financial Conduct Authority (FCA). FIE promotes the investment management services of both itself and its parent company, Fisher Asset Management, LLC (FAM), to retail clients in the UK and professional clients across Europe. FIE also serves as distributor to Fisher Investments Institutional Funds plc, an Undertaking for Collective Investment in Transferable Securities (UCITS) for which the parent company serves as investment manager.
This document, approved by the Board of Directors of FIE 12 November 2019, is to communicate FIE’s approach to conducting its UK tax affairs in accordance with the requirements of paragraph 16(2) of Schedule 19 of the UK Finance Act 2016 for FIE’s financial year ended 31 December 2018.
Compliance – FIE will ensure compliance in accordance with applicable tax laws and regulations in the jurisdictions in which it operates.
Accountability – FIE will maintain a governance framework that ensures clear accountability and oversight for all tax activities.
Relationships – FIE will build working relationships with its internal and external stakeholders by proactively advising them of the tax considerations of current and future decisions.
People – FIE will continuously train its personnel with the skills, knowledge and technical expertise to effectively and accurately fulfill their tax responsibilities.
FIE’s reputation is of utmost importance and FIE aims to comply with all UK rules and regulations, including tax regulations, to maintain a positive reputation in the eyes of clients, prospective clients and regulators (including the HMRC).
FIE delegates tax management to its parent company, with FIE tax team based at FAM in the US (the Tax Team). This Tax Team is responsible for monitoring and identifying tax risks and applies technical expertise to address any issues and consults with other impacted departments or business units as required. Each department will implement new policies and procedures to address areas of tax risk if needed. Where internal expertise is not available or complex issues arise, external service providers are consulted to assist in assessing tax risk, determining how it applies to FIE’s fact pattern, and identifying solutions.
The Tax Team informs the board of directors of tax issues and request their input, where needed.
FAM’s Executive Vice President of Corporate Finance is responsible for ensuring that FIE’s tax risks are identified, quantified and, if necessary, escalated to senior management. The Tax Team is responsible for day-to-day management of tax operations and identifying areas of risk.
To ensure FIE’s tax compliance requirements are met and FIE’s reputation is upheld, the Tax Team has various trackers in place to ensure compliance tasks, including filing tax returns and making tax payments, are completed on a timely basis. Where necessary, the Tax Team uses external advisors to assist them with tax filings. Internally, there is a rigorous three-tier review process to ensure that tax filings are made accurately. The Tax Team receives regular updates on relevant issues through external tax providers, which are internally reviewed along with the business fact pattern to determine if changes in tax legislation apply to FIE. This keeps the Tax Team up to date with changes in tax legislation and allows for implementation of new policies or procedures to comply with legislation where needed.
The Tax Team also educates various departments within FIE on relevant tax issues so management can make better business decisions and pro-actively include the Tax Team in decision making on all business changes.
FIE has a low tax risk appetite, which is aligned to the wider Fisher group tax risk appetite. This means the Fisher group does not engage in positions that have medium or high risk of resulting in a negative outcome or damage to Fisher’s reputation with government agencies, clients, or prospective clients.
FIE seeks to be as effective and efficient in tax planning, including taking advantage of any legitimate tax incentives which aid cash management. However, FIE is conservative in its overall approach and only undertakes planning in a commercially driven context. FIE’s primary tax objective is compliance with all tax rules and regulations in the jurisdictions FIE operates. Should any tax planning be proposed by the Tax Team, the planning must be approved at the executive or senior management level to ensure it has been properly prepared and is aligned to FIE’s objectives.
FIE does not engage in tax evasion in any form, nor does it tolerate the facilitation of tax evasion by any persons associated with or acting on behalf of FIE. FIE has not, and will not, engage in aggressive tax avoidance schemes, nor does it engage with those that seek to do so.
FIE strives to maintain an open and transparent relationship with HMRC and work proactively to resolve enquiries should they arise. Where HMRC requests for further information from FIE, FIE responds in a timely and collaborative manner, fully cooperating with requests to conclude any queries as efficiently as possible. FIE are committed to paying the appropriate amount of tax in compliance with UK tax legislation.