Tax Strategy Statement – September 2025

This statement sets out Pool Reinsurance Company Limited’s (“the Company’s”) approach in relation to taxation, in accordance with paragraph 16(2) of Schedule 19 of the Finance Act 2016. It applies to the Company and its subsidiaries and is reviewed and approved annually by the Board.

Our strategy reflects the Company’s commitment to integrity, transparency, and compliance. We aim to manage tax risk in line with our broader governance framework, maintain a low tolerance for tax risk, and foster a cooperative relationship with HMRC.

 

1. Governance and Risk Management

The Company manages tax risk as part of its overall risk management framework. Responsibility for tax governance lies with the Chief Finance & Investment Officer, supported by the finance team, risk management function, internal auditors and external advisers.

Key governance principles include:

  • Maintaining clear lines of responsibility and accountability.
  • Aligning our tax strategy with corporate governance and risk management policies.
  • Applying professional diligence and care in managing tax matters.
  • Escalating any tax issues to the Risk Committee and ultimately to the Board as required.
  • Keeping our resourcing under review and continuously seeking ways to improve how we govern tax in our Company.
  • Undertaking annual review and Board approval of the tax strategy.

Pool Re’s tax strategy reflects the company’s commitment not to facilitate tax evasion and complies with the Criminal Finances Act 2017.

 

2. Approach to Tax Compliance

Pool Re adopts a straightforward and transparent approach to its tax compliance, recognising both its legal and social responsibility to pay the appropriate amounts of tax in each jurisdiction it operates.

Tax arrangements are simple, well-understood, and based on generally accepted standards.

When making tax decisions, the Company considers:

  • The principles of the Managing Public Money handbook.
  • Alignment with corporate values and policies.
  • Impact on corporate reputation.
  • Relationship with HMRC and other tax authorities.

Where uncertainty exists, Pool Re seeks advice from third-party tax advisers to support decision-making.

 

3. Risk Appetite

Pool Re maintains a low tolerance for tax risk. The Company aims to minimise disputes with HMRC by being open and transparent about its tax affairs.

Key practices include:

  • Sharing details of significant transactions with HMRC before implementation.
  • Assessing proposed management actions on their commercial merit, compliance with Managing Public Money, and their regulatory and legislative impact on stakeholders.
  • Avoiding interpretations of tax law that conflict with our objective to remain compliant with our tax obligations.

The Finance team collaborates with business functions to ensure compliance, supported by external advice when necessary.

 

4. HMRC Engagement

Pool Re is committed to openness and transparency in its dealings with HMRC. All interactions are conducted in a collaborative, courteous, and timely manner.

Pool Re adheres to HMRC’s Framework for Cooperative Compliance by:

  • Maintaining open and collaborative professional relationships with HMRC.
  • Making fair, accurate, and timely disclosures; and responding to queries and information requests in a timely manner.
  • Seeking to resolve issues with HMRC in real time where possible.
  • Ensuring openness and transparency in decision-making.
  • Reasonably believing that transactions are structured in line with legislative intent.
  • Interpreting laws reasonably and consistently.

 

HMRC last reviewed Pool Re’s business risk in August 2023 and confirmed its ‘low risk’ status.

Pool Re annually submits a Senior Accounting Officer (SAO) certification to HMRC, confirming appropriate tax accounting arrangements.  The SAO certification is designed to foster better engagement between the Company and HMRC.  It provides a regular review process for the Company to demonstrate that its tax arrangements are fit for purpose.

This strategy is owned by the Chief Finance & Investment Officer and approved by the Board. It is reviewed annually.