Scope and application
This document sets out Danske Bank's strategy and approach to conducting its tax affairs in the UK.
This strategy applies to the list of entities set out below and is in respect of the financial year ending 31 December 2019. In this document, references to “Senior Management” are to the executive management of a UK subsidiary or representative office (a “Branch”).
Danske Bank regards the publication of this tax strategy as complying with the duty under paragraph 16(2) Schedule 19 Finance Act 2016 to publish a tax strategy.
Risk management and governance arrangements
Danske Bank's Tax Policy sets out the group’s approach to conducting its tax affairs in a transparent and responsible manner. The policy is mandatory across all Danske Bank related entities and has been reviewed and approved by the Board of Northern Bank Limited (“NBL”). It is the responsibility of Senior Management to ensure that the tax policy is implemented and adhered to in the Branch.
The Chief Financial Officer (“CFO”) of NBL, who sits on the Board of NBL, has ultimate responsibility for tax in NBL. Day-to-day management of NBL’s tax affairs is delegated to the UK Head of Tax, who reports to NBL’s CFO and the Head of Group Tax. The UK Head of Tax updates the Board Audit Committee of NBL at least annually on the Bank’s tax affairs and risks during the year.
Ultimate responsibility for tax in a Branch rests with Senior Management. The Senior Management may wholly or partly delegate or transfer responsibilities for tax to another Danske Bank related entity or group function, including Group Tax. Group Tax and Senior Management will annually identify and map the functions or staff responsible for day-to-day management of the Branch’s tax affairs including delegation of tasks and responsibilities.
Group Tax will also evaluate the Branch’s adherence to the Tax Policy and may address cases of non-compliance to the Group CFO. The Group CFO will report any material taxation issues to the Danske Bank A/S Board.
Danske Bank aims to employ and train in-house staff to ensure the bank has adequate tax skills to comply with tax law. Danske Bank recognises that tax law can be complicated, and uncertainty may arise in relation to particular tax positions. Where such situations arise or there is a lack of resources in-house, the bank may seek the advice of external advisers, thereby minimising any tax risk.
Attitude towards tax planning and level of risk
Danske Bank's Tax Policy sets the standards for the Bank’s conduct of business in relation to its UK tax affairs. The Tax Policy comprises three principles:
- That the Bank is compliant;
- That the Bank is transparent; and
- That the Bank will not be involved in illegal or abusive tax arrangements
Danske Bank has formally adopted and complies with HMRC's Code of Practice on Taxation for Banks, which sets out the principles and behaviours expected of banking groups with regard to tax.
Relationship with HMRC
In accordance with its Tax Policy, Danske Bank is transparent, seeks a pro-active, open and cooperative relationship with HMRC, and ensures that HMRC is kept aware of significant transactions and changes in the Bank’s business.
List of entities covered by this Tax Strategy
- Northern Bank Limited
- Northern Bank Executor and Trustee Company Limited
- Northern Bank Factors Limited
- Northern Bank Nominees Limited
- Northern Bank Pension Trust Limited
- Danske Bank A/S UK Branch