Banque Transatlantique

BANQUE TRANSATLANTIQUE SA LONDON BRANCH (BTLB) TAX STRATEGY FOR THE UK

Background

Founded in 1881, Banque Transatlantique is one of France’s most established private banks. Banque Transatlantique SA London Branch (‘BTLB’) specialises in private banking, financing and investment management services.

BTLB is fully owned by France’s fourth largest banking group, Crédit Mutuel Alliance Fédérative (‘Group’) via CIC-Crédit Industriel et Commercial and Banque Transatlantique SA.

This Tax Strategy document

This Tax Strategy is applicable to BTLB tax activities as they relate to UK taxation.

This document meets the requirement for BTLB to publish its Tax Strategy as required by section 161 and paragraph 19(4) of Schedule 19 of Finance Act 2016. It is effective for the accounting period ended 31 December 2017 and is relevant for BTLB.

BTLB Tax Principles: Tax Compliance and Reporting

BTLB recognises that it has an obligation to pay all taxes required by law and regulations in each of the jurisdictions in which it operates, including the UK. The Group operates with the highest integrity to comply fully with tax laws and to maintain a co-operative and professional relationship with all tax authorities, HMRC being just one of these.

Compliance with all laws and regulations, including those relating to tax are firmly embedded in the business and BTLB has an established internal control system and procedures to help achieve this.

This includes seeking to apply diligent professional care and judgement in tax compliance activities, and providing sufficient evidence to support all judgements made.

BTLB’s approach to risk management and governance arrangements in relation to UK taxation

The risk management function is embedded through a ‘three lines of defence’ model. Primary controls are implemented in the Finance Department of BTLB. This Department regularly reviews key activities to identify key current and emerging risks. Key risks, controls and related actions are reported, monitored and tracked in accordance with internal risk reporting requirements.

The Compliance Function performs a second level of governance through the assessment of internal controls. BTLB is subject to the wider Group’s Internal Audit Plan, which provides a further level of control.

BTLB seeks to reduce tax risk arising from its operations through an ongoing commitment to improving control effectiveness and by ensuring that all calculations and processes relating to the submission of information to HMRC are undertaken by appropriately qualified staff.

BTLB staff managing day to day tax matters are appropriately qualified and trained with formally defined roles and responsibilities.

All tax returns are subject to detailed internal checks.

The Head of Finance of BTLB is responsible for the tax function and for the tax risk management. The Head of Finance of BTLB is responsible for the identification, prioritisation and monitoring of tax risk across the UK business, as well as the escalation of tax risk to the BTLB General Manager.

The BTLB General Manager is ultimately responsible for all of BTLB’s activities and reports directly to the Head of Private Banking and Wealth Management at Banque Transatlantique and the Directoire (Company Directors) of Banque Transatlantique.

The Directoire provide oversight in ensuring that tax is considered within the wider context of the business and in how tax risk is managed across the Group. Compliance and risk matters, including those concerning taxation, are included on the agenda at board meetings.

Where there is significant uncertainty or complexity in relation to tax risk, BTLB seek input from external advisors.

BTLB’s approach towards tax planning in relation to UK taxation

BTLB applies a prudent approach to tax risk when evaluating transactions. Moreover, BTLB is fully committed to comply with the UK Code of Practice on the Taxation of Banks and the rules in respect of the Disclosure of Tax Avoidance Schemes.

BTLB has a low risk appetite to tax planning as it affects UK taxation, and tax decisions are aligned to business and commercial strategy. BTLB may respond to tax incentives and reliefs where appropriate and in a way that is consistent with HMRC and government policy.

As appropriate, BTLB will seek external professional tax advice to ensure these incentives and reliefs are applied legitimately, particularly if the outcome of a transaction is uncertain or complex. If appropriate, BTLB will seek advance clearances with HMRC to ensure the risk of uncertainty is minimised.

This approach to tax matters ensures that BTLB comply with applicable legislation requirements and HMRC guidance.

Transparent and professional relationship with HMRC

BTLB seeks to maintain an open and transparent relationship with HMRC through regular dialogue in respect of the business, tax risks and the interpretation of the law in respect of all relevant taxes. Through this regular dialogue with HMRC, BTLB seek to provide explanation and certainty in advance.

This Tax Strategy has been developed by the Head of Finance

Approved by the Board