In making this strategy available the Cigna UK Group1 is fulfilling its responsibilities under paragraph 16(2) Schedule 19 FA 2016 for the year ended 31 December 2023. This UK tax strategy has been approved by the Cigna European Finance Director who has designated authority issued by the Board of Directors of Cigna Life Insurance Company of Europe SA-NV and Cigna Europe Insurance Company SA-NV (the “European Board”) to be published in satisfaction of these requirements, and applies to Cigna European Services (UK) Limited (“CESL”) and all entities listed at Appendix I, hereon referred to as “the UK Group” 2.
In relation to tax, the UK Group considers itself to have a low threshold for risk and accordingly places high importance on complying with all statutory obligations, be they tax or regulatory.
The UK Group manages tax risk as part of its wider internal risk management process, with a view to ensuring that tax returns and reporting are accurate, timely and in compliance with all applicable laws and requirements. This wider internal risk management process is also applied to changes to the business including, but not limited, to changes to the group structure, financing arrangements and acquisitions.
Ultimate responsibility for the UK Group’s tax strategy lies with the European Board, with executive management of tax delegated to our European Finance Director. Our European Tax Manager 3 is responsible for the day-to-day oversight of our tax affairs in the UK and reports directly to the European Finance Director on all significant tax matters, such that tax developments and risks are considered at the European Board level on a case-by-case basis.
Tax risks and the operational effectiveness of controls around tax processes are periodically reviewed and considered by the Board. The European Audit Committee 4 meets with the European Board on a quarterly basis, and discusses all significant risks, including tax risks, such that these are monitored on an ongoing basis.
The tax function comprises a team of professionals with the appropriate knowledge, experience and capabilities to manage the UK Group’s tax affairs and maintain oversight of the tax risks emanating across the UK Group. Our in-house tax team keeps abreast of developments in tax law and practice through attendance at training seminars, and has access to major tax intelligence resources. They also receive regular mailings from professional advisers to ensure developments in the legislative environment are monitored.
From time to time there may be instances where we face uncertainty as to the interpretation and application of certain tax laws, and/or a transaction or activity which may have a material impact on our finance position. In such instances, we consult internally and may seek external advice to ensure our interpretation is appropriate, taking into account both the spirit and the letter of the law, and the underlying commercial position taken by the UK Group.
We have appropriate guidance in place to support the tax team and all UK Group tax returns undergo multiple levels of review, including review by the European Tax Manager prior to submission.
Reasonable care is applied in relation to all processes which could materially affect our compliance with our tax obligations. Tax risk is managed in a way such that it does not pose a threat or cause damage to the reputation of the business or impact our financial performance.
It is our desire to achieve certainty in our tax affairs. Effective risk management is paramount to the business and our appetite towards tax risk is aligned with our strategic business objectives. Our ongoing approach to tax risk is based on the principles of reasonable care and materiality. We assess risks on a case by case basis but do not seek to go beyond the spirit of the UK tax rules and seek certainty in our tax positions.
Our focus is on compliance with regulations and the detection and management of tax risks through our procedures and controls. The UK Group’s tax team is suitably qualified and experienced to make such judgement calls including the need to consult where significant levels of uncertainty are present, be this internally or with professional advisors. As a UK Group we consider ourselves to have a low threshold for tax risk.
We conduct our tax affairs in line with our code of ethics, maintaining our reputation as a good corporate citizen, by ensuring our tax analyses and considerations reflect the commercial reality of the business operations.
To maintain competitiveness, where there are opportunities for statutory tax reliefs, as laid out in the UK legislation, we would seek to pursue such tax reliefs in line with the law and the commercial reality. Where applicable, we take advice from professional advisers and HMRC to confirm our interpretation of the law.
This approach is driven by our desire for certainty in our tax affairs and is grounded in our values.
All dealings with the UK tax authorities are undertaken in a courteous, collaborative and timely manner. Our tax function represents the UK Group in its interaction with HMRC and their priority is always the integrity of our tax affairs and the maintenance of an open and honest relationship.
Our tax submissions are prepared on a full disclosure basis and while every effort is made to ensure all tax filings are accurate, where errors in submission are identified, we notify HMRC of these promptly and engage fully to rectify the position.
1The Cigna UK Group hereby refers to all UK domiciled Cigna companies listed per Appendix 1
2European Board has delegated authority for the UK Group and all other Cigna entities within Europe
3Employee of Chestnut Holdings but responsible for the UK Group and all other Cigna entities within Europe
4Audit Committee of CLICE/CEIC with delegated authority for the UK Group
Appendix 1 – Tax Strategy Applicable to following: