Clinigen Group plc is a trusted global leader in the highly regulated pharmaceutical industry, listed on the Alternative Investment Market of the London Stock Exchange and operating in three areas of global medicine supply: Clinical Trial, Unlicensed and Licensed Medicines.
Our mission is to deliver the right medicine to the right patient at the right time. The Group supplies critical lifesaving medicine, to customers in over 129 countries, shipping over 6 million units annually. Our business activities incur a substantial amount and variety of taxes, including corporate income tax, business rates, stamp taxes, and in the UK, employer’s national insurance. In addition, we collect and pay employment taxes and indirect taxes such as VAT.
Clinigen’s core values, outlined in “The Clinigen Way”, encourage honesty and transparency, and we pride ourselves on our integrity and openness and empower our staff to challenge management if these principles are not adhered to.
In accordance with Paragraph 16 of Schedule 19 to the Finance Act 2016, this strategy has been published online and applies to Clinigen Group plc and all its UK subsidiaries and applies from the date of publication until it is superseded.
Our approach to risk management and governance
Clinigen identifies and manages risks and opportunities, including tax risk, that may affect the achievement of its strategic objectives and business plans, its shareholder value and its reputation, through its risk management process. The Board has responsibility for establishing and maintaining the Group’s internal control systems which are monitored by the Audit and Risk committee to ensure compliance with laws and regulations. The Group Chief Financial Officer provides updates to the Board on key risks and controls within the Group.
Tax risk arises due to the complexity of tax legislation and potential differences in interpretation, and in relation to Clinigen’s business operating model. Clinigen has established policies and procedures to ensure the integrity of its tax filings and other tax compliance obligations in the UK and worldwide, and our processes are subject to the same level of internal controls, review and external audit as the rest of the business. Tax risk is viewed no differently to any other business risk encountered.
For routine and established tax compliance procedures we have a very low tolerance of risk and aim for a high standard of accuracy and compliance with reporting procedures and deadlines.
Clinigen has appropriately qualified finance resource who receive the necessary guidance and training to keep up to date with new tax legislation and are supported to seek additional professional tax advice where appropriate. The finance resource maintains regular lines of communication with the commercial and functional teams across the business to ensure the tax effects of business developments are identified and understood.
Our attitude to tax planning
We have a responsibility to our shareholders to ensure our operations and financial activities are conducted in a tax efficient manner. We aim to structure our operations and finances in a tax efficient manner which may include tax planning. This tax planning is seeking to maximise shareholders value by utilising available tax reliefs, incentives and exemptions where appropriate and ensuring that any arrangements are in the spirit of and comply with the tax legislation in question.
Professional advice is sought on a transactional basis, with the depth of that advice driven by our assessment of the risk presented and level of complexity involved.
Level of tax risk we are prepared to accept
Clinigen’s approach to tax planning is to ensure compliance with tax laws and regulations, both in the UK and worldwide, and to ensure that we identify and mitigate tax risks. Tax risk is assessed for each significant transaction. We have no defined limit of the risk we are prepared to accept, we will assess, manage and mitigate the tax risk to an acceptable level on a case by case basis. We maintain relationships with reputable external tax advisors that allow us to seek expert advice on specialist areas of tax, and in situations where the tax law is unclear or where internal expertise is insufficient.
Our approach to dealing with tax authorities
Clinigen seeks to ensure its engagement with HM Revenue and Customs (and other tax authorities in other jurisdictions) is professional, open and honest and undertaken in the spirit of cooperation. Our aim is to work collaboratively and proactively with tax authorities to resolve matters arising which may include areas such as where legislation or guidance is unclear and there is a significant tax impact. We aim to respond to requests for information in a timely manner and we submit all returns on time. Where appropriate the Group seeks advance clearance from tax authorities on the proposed tax treatment of transactions.