CRF Health Tax Strategy
This document sets out the tax strategy for CRF Health Group Limited (“the Group”) and all UK subsidiaries, covering all UK taxes and duties. The strategy has been approved by the Group’s Chief Financial Officer (“CFO”) and satisfies the Group’s requirements under Schedule 19 of the UK Finance Act 2016 in respect of the period ending 31 March 2018.
The majority of the issued share capital of the Group is held by VIP II Nominees Limited, which is ultimately under the control of Vitruvian Partners LLP, an independent European private equity firm.
The Group’s principal activity is the provision of electronic Clinical Outcomes Assessment (“eCOA”) solutions for the life sciences industry. eCOA solutions encompass Patient Reported Outcomes (“PRO”), observational reported outcomes and clinician or rater reported outcomes. The Group’s ePRO technology has been used worldwide, in six continents and in over 150 languages. From a collaborative, agile design approach to user-friendly reporting tools, CRF streamlines complex processes and deliver reliable results for superior clinical trial outcomes. CRF improves patient engagement with intuitive design, support study teams with tailored scientific insights, and secure high-quality data with precision.
CRF is innovative, results-driven, and deeply committed to our customers. We believe each and every person in our company plays a part in our success—our employees are proud, passionate, and own their contributions, both individually and in collaboration with an inspiring team of colleagues. Our open, collaborative culture encourages employees to develop new skills and make new connections.
5Our overall aim for tax is to support delivery of the commercial objectives of the Group in an efficient and compliant manner that aligns with the Group’s ethical business practices that are in place to support the highly regulated industry in which it operates. Delivery of this tax strategy is supported by tax and finance controls which will be supplemented by our Tax Governance Policy and Tax Risk Register that are being developed and will align to our overall Group approach to risk management.
Approach to tax risk management and governance
The Tax Strategy is reviewed and approved by the CFO who has overall ownership of this document. The finance team have day-to-day responsibility for its delivery and ensuring compliance with all statutory filing, reporting and payment obligations with the support of outsourced tax compliance advisors. Processes and controls that are proportionate to the size and complexity of the Group’s operations are in place to mitigate tax risks. These controls are supported by documentation contained within the Group’s Quality Management System (“QMS”). There are also other frameworks such as the Group’s Schedule of Delegated Authority (“SoDA”) that covers all key business processes, many of which could have a significant impact on tax. These all support the submission of the Group’s annual Senior Accounting Officer (SAO) certification.
Members of the finance team who have a responsibility for tax have access to suitable training and guidance. We also work closely with external advisors to ensure that significant tax risks are appropriately managed in line with the tax risk appetite of the Group. The finance team work closely with the business as partners to provide clear, timely, relevant and business focused advice across all aspects of tax risk. The CFO is also closely involved in all key business and operational decisions to ensure that tax are appropriately considered in line with this strategy.
Implementation and use of our Tax Risk Register will allow the Group to identify and manage risks on a regular basis and in a way that is aligned to our acceptable level of tax risk. It will be reviewed regularly and material or significant tax decisions and risks will be reported to the Board by the CFO if and when they arise. Individuals with responsibility for tax and finance are supported by appropriate policies, controls and process that are designed to minimise the tax risks that may arise on a day-to-day basis. This approach enables the Group to manage the impact that tax risks may have on the business in line with this Tax Strategy.
Level of risk we are prepared to accept
The Group’s tax risks are managed in accordance with our ethical business practices and QMS documents. This is aligned to the wider business approach to risk management which includes use of the SoDA. Our operations are also only structured based on sound commercial and business principles. The Group’s approach to tax risk management and level of risk that is acceptable based upon this, will be clearly defined within our Tax Governance Policy.
Although we aim to minimise tax risk wherever possible, we acknowledge that the elimination of all tax risk is impractical due to the complexity of tax legislation and differences in interpretation that may arise. Where significant or unusual tax positions are identified we will seek external advice to ensure that the associated risk is appropriately managed. We may also engage with tax authorities in relation to certain tax positions, as is outlined below.
Attitude towards tax planning
We strive to be tax efficient in order to grow our business and support commercial objectives, but we will not enter into any aggressive tax planning arrangements and only commercially driven transactions will take place. Where different routes exist to achieve the same commercial outcome then the most tax efficient option will be considered but only if it is supported by sound business principles and aligns to our ethical business practices.
This strategy has also been communicated to external advisors to ensure that any advice provided complies with it. Our Transfer Pricing policy is based on the principle of conducting transactions on an arm’s length basis with consideration of the OECD Guidelines. We will also take advantage of all available tax reliefs, incentives and exemptions that are made available by tax authorities.
Approach towards dealing with tax authorities
We are committed to an open and transparent relationship with tax authorities. The CFO is our SAO and has overall responsibility for our relationship with tax authorities. Where any dialogue with tax authorities is required, we are committed to disclosure of all of the relevant facts on a timely basis. We will also work with tax authorities to answer any queries or resolve any differences in a timely and professional manner.
We aim to comply with all applicable tax laws and regulations and to do so will engage with external tax advisors when significant transactions are undertaken or in areas of uncertainty. We may seek guidance or clearance from tax authorities in relation to specific historic, current or future events where they are significant or where there is uncertainty regarding the interpretation of tax law.