SLF UK - Tax Strategy

This Tax Strategy applies to the SLF of Canada UK Limited group of companies and Sun Life Financial of Canada (U.K.) Overseas Investments Limited (referred to as “SLFoC UK”).

The Tax Strategy for SLFoC UK sets out our approach to the management of SLFoC UK tax affairs in supporting business activities in the UK.

We aim for our tax affairs to be well governed and transparent, meeting all legal requirements and mitigating tax uncertainties. We have an open, transparent, co-operative and constructive relationship with HM Revenue and Customs (“HMRC”).

We review our Tax Strategy every year and it is approved by the Board of the main operating company, Sun Life Assurance Company of Canada (U.K.) Limited.

SLFoC UK’s approach to effective tax risk management and governance

We use a framework of policies, procedures and internal controls to manage our tax risks.  Our management team, Risk and Internal Audit functions review our policies regularly.  Compliance with regulation, legal and ethical standards is a high priority for SLFoC UK.

We actively manage the tax risks affecting our business and aim to minimise unexpected adverse financial impact.

SLFoC UK’s attitude towards tax planning

We make management decisions after careful consideration of all the key metrics, including the regulatory, legal, accounting and tax implications in line with our risk management framework. Where we identify tax issues from a proposed management action, we analyse and understand them to ensure that there are no unintended tax costs. Whilst the management of the SLFoC UK’s tax affairs contributes to achieving business objectives, we base all management actions on an underlying business purpose with commercial and economic substance. We do not engage in tax planning which is considered abusive or enter into transactions or arrangements where the main purposes is the avoidance of tax.

Where there is uncertainty about how a transaction is taxed, we will discuss it with HMRC and take external advice where appropriate. We may also use external advisors to provide specialist expertise or to help us to understand new tax legislation or industry practice.

SLFoC UK’s assessment of acceptable tax risk

The way in which we assess and manage acceptable levels of tax risk is consistent with that used across SLFoC UK for managing other risks within the risk management framework. We have low tolerance for the risk of tax return errors or omissions, or late submissions or tax payments as part of our tax compliance obligations. We also have low tolerance for losses suffered as a result of failing to develop, implement and monitor controls to manage our tax risks.

We report all material tax risks as part of the risk management process to the Risk and Compliance Management Committee.

SLFoC UK’s approach to dealings with HMRC

We seek to maintain an open, transparent, co-operative and constructive relationship with HMRC, engaging with honesty, integrity and fairness. In certain situations, we may engage with HMRC on a real time basis to agree or understand the operation of tax legislation. We aim to discuss any significant issues before filing tax returns so that we are able to conclude any tax issues in a timely manner. At HMRC’s Business Risk Review meeting, we discuss tax issues and provide HMRC with the opportunity to understand our business and to discuss our tax strategy and business developments.

The above information published in November 2017 complies with our duty to disclose our UK Tax Strategy as set out in Paragraph 16(2) Schedule 19 Finance Act 2016 for the year ended 31 December 2017.