This tax strategy outlines ACCA’s commitment to meet our tax obligations.
ACCA is the Association of Chartered Certified Accountants. We are a thriving global community of 227,000 members and 544,000 and future members based in 176 countries that upholds the highest professional and ethical values. Our purpose is to be a force for public good and lead the global accountancy profession by creating opportunity.
We believe that accountancy is a cornerstone profession of society that supports both public and private sectors. That’s why we’re committed to the development of a strong global accountancy profession and the many benefits that this brings to society and individuals.
Since 1904 being a force for public good has been embedded in our purpose. And because we’re a not-for-profit organisation, we build a sustainable global profession by re-investing our surplus to deliver member value and develop the profession for the next generation.
Through our world leading ACCA Qualification, we offer everyone everywhere the opportunity to experience a rewarding career in accountancy, finance and management. And using our respected research, we lead the profession by answering today’s questions and preparing us for tomorrow.
This document, approved by the Executive Team of the Association of Chartered Certified Accountants, (“ACCA”) is published in accordance with the requirements of Schedule 19 of the Finance act 2016 and is effective for the year ending 31 March 2021.
Our tax strategy is periodically reviewed and revalidated annually. It is revised as appropriate to reflect any material changes in our business or in tax legislation, with any amendments approved by the Executive Team.
ACCA is operating in an increasingly complex global environment, in many jurisdictions with evolving tax regimes. To ensure that our tax affairs are consistently managed ACCA’s tax strategy is applied to all taxes in all countries where we operate.
We manage and report our tax affairs in compliance with fiscal obligations and consistent with international best practice guidelines such as international accounting standards and OECD Guidelines for Multinational Enterprises.
Our strategy is to ensure that ACCA pays, on time, the appropriate amount of tax commensurate with our activities performed in each country in which we operate. In particular we recognise the importance of the tax that we pay to the social and economic development of these communities.
ACCA is committed to conduct its tax affairs consistently with the following objectives:
- To comply with all relevant laws, rules, regulations and reporting and disclosure requirements wherever we operate;
- Ensure that the tax strategy is consistent with ACCA’s overall strategy, its approach to risk and its core values;
- Apply professional diligence and care in the management of tax risks, seeking external advice where appropriate;
- Ensure that tax matters are subject to the appropriate governance and assurance procedures;
- Develop and maintain constructive, professional and transparent working relationships with local tax authorities based on the concepts of integrity, respect and mutual trust;
- ACCA will use incentives and reliefs where provided by local legislation where these are consistent with the substance of our business and with full regard to the aims of our stakeholders, our reputation and our broader social and economic goals.
We ensure compliance with our tax obligations by maintaining appropriate tax management arrangements, including the roles and responsibilities taken on by our people and invest in our systems, processes and technology to support a suitable tax control environment.
The Executive Director, Finance and Operations, as the Senior Accounting Officer is responsible for both the management of tax risks throughout ACCA and for ensuring that the tax strategy is applied consistently across its tax affairs. The Finance Director supports the Executive Director, Finance and operations in the role of Senior Accounting Officer on a day to day basis.
The consideration, assessment and proactive management of risk forms an integral part of the way ACCA operates. Our Enterprise Risk Management approach helps link strategy and risks, as clearly as possible, so that our decision making is transparent and based on robust evidence.
We invest significant effort in ensuring we have appropriate and robust mechanisms in place to illuminate, escalate and effectively manage risks to our organisation, our members and the accountancy profession in general.
Due to the global nature and volume of our business, combined with the scale and variability of our tax obligations and the need to interpret increasingly complex and evolving legislation across a range of territories, the emergence of compliance risks, including tax obligations, is inevitable.
Where we identify such risks we actively seek to mitigate these in accordance with our risk appetite. Our risk appetite sets out how we balance risk and opportunity, across a variety of areas, to ensure we continue to operate in an ethical and professional manner that supports the public interest and society in general.
ACCA’s Executive Team is accountable to our Council Board for ensuring ACCA effectively manages risk in alignment with its Enterprise Risk Management approach. The Executive Team determines the organisation’s overall appetite for risk, including tax risk, and this is reviewed on a regular basis.
Risks are managed within a hierarchical framework across ACCA’s executive directorates at the operational level closest to the risk, by persons with the competence and capacity to do so. Where risks are deemed to be moving outside the sphere of control of the current hierarchy a formal escalation process exists to ensure risks receive the appropriate level of oversight in accordance with their assessed level of threat.
The central risk team within ACCA reviews and provides ‘independent challenge’ of all risks and associated controls to ensure they are being managed in a consistent fashion and in consideration of ACCA’s risk appetite.
Our Audit Committee, comprising of Council Members provides assurance, by exercising independent oversight, to ACCA’s Council Board regarding the effectiveness of ACCA’s risk management approach and control environment.
Collectively the Executive Team has ultimate accountability for the tax risks and how that is addressed by the organisation.
Managing Tax Risks
Our approach to managing tax risk concentrates on Operational Tax risks which we define as any failure in compliance that adversely affects ACCA’s objectives or results in controversy, penalties, assessments or harm to our people or reputation.
Tax risks are principally reported and addressed using suitable tax risk management tools within the Finance and Operations Executive Directorate, Our risk management procedures include roles and responsibilities across the organisation, various risk management processes and systems, compliance monitoring and internal audit reviews of operations, all designed to minimise the risk of tax controversy and reputational risk.
Professional care and judgement are employed to assess tax risks and how these should be managed. Where there is uncertainty as to the application or interpretation of tax law, ACCA will take appropriate written advice from third parties evidencing the facts, risks and conclusion to support the decision making process.
All strategic or planning opportunities are presented by the Head of International Tax and Treasury to the Executive Team of ACCA for consideration and approval prior to implementation. Further oversight of the tax strategy and associated implementation matters is provided by the Council Board of ACCA on a regular basis and no less than annually.
Relationships with Tax Authorities
ACCA believes it should pay the amounts legally due in any territory where it operates. There may however be circumstances where this is not clearly defined or is subject to interpretation that may result in differing tax outcomes. ACCA will use its best judgement when determining the appropriate course of action, (including obtaining the advice of third parties). However it may be necessary from time to time to engage with tax authorities to agree a tax position.
All dealings with tax authorities will be conducted in a collaborative, courteous and timely manner. ACCA is committed to the principles of openness and transparency in its approach to dealing with tax authorities and will aim for early agreement on disputed matters.
We shall proactively engage, either directly or through local advisors, with the authorities to ensure that our business and tax positions are understood, to achieve certainty where possible and to confirm our tax positions in a timely manner.
Our Approach to Dealings with HMRC
In accordance with these principles ACCA undertakes to:
- Adopt an open and collaborative professional relationship at all times with HMRC;
- Make fair, accurate and timely disclosure in returns to HMRC and respond to questions and information requests in a timely manner;
- Engage in full and early dialogue with HMRC including seeking advance clearance or agreement where appropriate, to provide certainty of tax treatment in significant transactions;
- Be open and transparent about decision making, governance and tax planning;
- Make timely submissions of tax returns and tax payments and where disagreements arise work with HMRC to resolve issues by agreement;
- Structure transactions, interpreting the relevant laws in a reasonable way, to give tax results that are only consistent with the commercial and economic consequences and not contrary to the intention of Parliament.
Adherence to our tax principles with its complementary focus on reputational risk underpins ACCA’s commitment to meet both our tax obligations and our wider strategic objectives.
This tax strategy was reviewed and approved by the Executive Team of ACCA in March 2020.