Brink’s UK Tax Strategy
This document sets out The Brink’s Company’s (“the Company”) policy and approach to conducting its tax affairs and dealing with tax risk, and is made available to all the Company’s stakeholders. It is intended to satisfy the reporting obligations of Schedule 19 of the Finance Act 2016, and is effective for the year ending 31 December 2016 until it is superseded. This strategy applies to all of the Company’s affiliates, including its UK operating affiliates: Brink’s Limited (UK), and Brink’s Global Services, Ltd.
The Company is committed to full compliance with all statutory obligations and full disclosure to tax authorities. The Company’s overall tax strategy aims to support its business by maintaining an appropriate tax rate, while mitigating tax risks and complying with the rules and regulations of the jurisdictions in which the Company operates. The Company seeks to balance its responsibilities for controlling tax costs with its responsibilities to pay tax where it does business.
Brinks is the world’s largest cash management company. Our customers include financial institutions, retailers, government agencies (including central banks and mints), jewelers and other commercial operations around the world. Our global network serves customers in more than 100 countries. We have ownership interests in companies in 41 countries and agency relationships with companies in additional countries. We employ approximately 60,700 people and our operations include approximately 1,000 facilities and 11,900 vehicles.
Brink’s was founded in 1859 and The Brink’s Company was first incorporated in 1930 under the laws of the State of Delaware (at that time, the Company was named The Pittston Company). It succeeded to the business of a Virginia corporation in 1986 and was renamed The Brink’s Company in 2003. The Company’s headquarters are located in Richmond, Virginia, United States, and the Company’s common stock is traded on the New York Stock Exchange.
Risk Management & Governance
The Company’s Board of Directors (the “Board”) has oversight of the Company’s strategy as well as compliance with applicable rules and regulations, including those related to tax. With input from various departments (including tax), the Board provides oversight of the Company’s risk management process. Local UK management teams are charged with day-to-day management of UK tax risk. The Company, its subsidiaries and affiliates maintain internal policies and procedures to support its tax control framework and provides training to its personnel to manage UK tax risk. The Company’s Vice President – Tax manages global tax risks.
The Company’s tax department works with local management to identify and manage UK tax risks using its knowledge of the Company’s operations and UK tax legislation. They do this by, for example, (i) regularly communicating with finance staff to keep informed of any significant business changes, (ii) monitoring proposed changes in UK tax legislation to identify its potential impact on the Company and (iii) being involved in all UK dispositions/acquisitions, including preparing or reviewing tax diligence reports. To help manage this process, the Company 1) utilizes technology software tools, and 2) assigned a dedicated UK tax representative.
Attitude towards tax planning and level of risk
The Company engages in appropriate tax planning to support its business and reflect commercial and economic activity. The Company does not engage in aggressive tax arrangements, the sole purpose of which would be to obtain a tax advantage. The Company does, however, have a responsibility to minimize its tax risk and potential damage to its reputation and brand (an important asset). The Company complies with all tax rules and regulations on a worldwide basis. The Company believes it is important to maintain its business operations in compliance with UK and foreign tax obligations. The Company considers the tax consequences of significant transactions before carrying them out and its tax department decides when to consult external advisors on the tax implications of a potential transaction, with the depth of such advice being driven by the assessment of risk presented by each transaction.
The Company’s tax arrangements are based on its commercial business and economic activities. The Company recognizes that there is inherent risk related to taxation due to (i) the complexity of taxes, (ii) the scope of disagreement over the interpretation of laws meaning that tax authorities may take a different view of the application of legislation and (iii) the variety and volume of different taxes that affect the Company’s activities. The Company monitors and reviews its operations in the UK and elsewhere to realign its tax arrangements when necessary to be compliant with the tax rules and regulations.
If a tax controversy does arise, the Company will evaluate all the facts and circumstances (hiring external advisors where appropriate) to determine the appropriate course of action, including whether to pay the tax or protest the issue.
Relationship with HMRC
The Company is committed to the principles of openness and transparency with tax authorities and adopts a proactive approach to raising tax issues and working collaboratively with local tax authorities wherever possible. The Company seeks to build and sustain relationships with local tax authorities that are constructive and based on the principles of cooperation and compliance.
Any inadvertent errors in submissions made to HMRC are fully disclosed as soon as reasonably practicable after they are identified.