Published 27 February 2023
At Starling Bank, we believe that good business and ethics go hand in hand. We believe that businesses should be aware of their social, economic and environmental impact and their responsibilities to pursue the social good. Our values shape our business, the way we work and who we work with. It is not just the result that matters at Starling; but how we do it.
We have set out below our tax strategy, which applies to all UK entities in the Starling Group in respect of the year ended 31 March 2023. This has been published in accordance with the requirements set out at paragraph 19(2) of Schedule 19 of the Finance Act 2016.
How we manage UK tax risks
We will not do anything in our tax affairs that runs contrary to either the letter or spirit of tax legislation in the UK and any other country in which we are liable for tax.
Our Board has ultimate responsibility for setting Starling’s tax strategy, risk appetite and control framework. Our Board-approved risk management framework applies to tax, and governs our approach to how tax risks are managed and reported. Starling Bank is a signatory to and complies with the Code of Practice on Taxation for Banks and is fully compliant with its obligations under the Senior Accounting Officer regime.
Starling is a lean and agile organisation. We are good at quickly identifying and assessing the tax impact of initiatives and transactions across the business in real time, and proactively supporting all parts of the business with tax matters. Material tax matters are rapidly escalated to the Board for review and approval. Ongoing and key tax matters are also reported to the Board monthly and governed by a Board approved Tax Policy.
The CFO has executive responsibility for tax and is supported on a day to day basis by the Head of Tax and the finance and tax teams. As part of our risk management framework, appropriate tax policies, procedures, controls, systems and people are in place and the tax function is periodically reviewed by the risk function and internal audit. External auditors also periodically review key tax matters.
We value certainty in our tax affairs and we regularly seek advice from external tax advisors, particularly in relation to complex or uncertain tax matters.
Our attitude to tax planning
All of our tax planning is carried out in line with our values and in order to achieve our strategic and operational objectives. This means we seek to keep it simple and pay the right tax, at the right time in the right jurisdiction. Also all of our tax planning supports genuine commercial outcomes and business activity.
We forward plan our tax affairs where possible, using external tax advisors to achieve certainty in our tax affairs. This helps to limit the risk of mistakes and reputational damage, and make sure tax results are consistent with the underlying economic consequences of a transaction.
We aim to comply with the spirit as well as the letter of the law. We only claim tax reliefs intended by Parliament and we do not use artificial or complex tax structures.
The level of risk we are prepared to accept
Our reputation, both with the general public and our current and potential investors, is important to us. To safeguard our reputation, and because we believe it is the right thing to do, we adopt a low-risk approach to both the governance and day to day running of all tax matters. This helps ensure that tax risk is managed in accordance with our values and does not adversely impact our reputation.
We take a zero-tolerance approach to tax evasion and we have implemented reasonable procedures across the group to ensure we do not engage in any form of facilitating tax evasion, whether in the UK or abroad. We expect all of our partners and customers to adopt the same values and principles as us.
How we work with HMRC
We maintain a transparent and collaborative relationship with HMRC, including pro-actively engaging with HMRC so they are aware of our future business plans and we disclose any significant transactions that could impact us from a tax perspective. We have, where appropriate, sought clearances from HMRC with regards to providing certainty on material tax matters.