The Finance Act 2016 requires all qualifying UK groups, and UK sub-groups of foreign groups, to publish their UK tax strategy. This statement is being made by The Arch Company Properties Limited, acting in its capacity of general partner of The Arch Company Properties L.P. (the “Partnership”).
The Partnership and The Arch Company Properties Limited (along with other entities) together comprise “The Arch Co Group”. The Arch Co Group is ultimately owned as a joint venture between TT CDR Assetco Limited (“TT Group”) and BX CDR Holdco Limited (“Blackstone”) (together the “JV Shareholders”).
The Partnership adopts an open and transparent relationship with the UK tax authorities. All taxes, duties and similar charges are intended to be paid according to the UK laws and regulations in a timely manner.
Staff, responsibilities and governance
TT Group and Blackstone each nominate directors to form a board for The Arch Co Group. This board, the Arch Company Joint Venture Board (the “JV Board”), is responsible for the statutory activities of the Partnership, and delegates the operation of the Partnership to the Chief Executive Officer (“CEO”) of The Arch Co Group and its operational committees.
The Partners are accountable for the Partnership’s tax strategy. The Finance Director and Tax and Treasury Manager of The Arch Co Group keep the tax personnel of the JV shareholders informed of material tax matters relating to the Partnership.
The Arch Co Group has an in-house Tax and Treasury Manager who is responsible for the day-to-day tax compliance of The Arch Co Group, including the Partnership, the majority of which is completed in-house.
Where external advisers are used, their work is subject to review and approval by the Partnership’s Tax and Treasury Manager to ensure compliance with The Arch Co Group’s tax policy and corporate values. The use of such advisers is also subject to JV Board oversight.
Tax risk and planning
The Partnership is a commercial enterprise with a responsibility to deliver profits for its JV Shareholders. All decisions are taken with a strong commercial rationale.
The Partnership abides by the rules and regulations in the UK and takes a conservative approach to tax planning. The Partnership does not make use of marketed tax schemes.
In the UK, the Partnership has an HMRC Corporate Compliance Manager (“CCM”), with whom the Partnership communicates to discuss relevant matters and provide updates.
Tax risk is managed by:
- Having a highly qualified and experienced tax professional in-house
- Utilising the JV Partners’ in-house highly qualified and experienced tax professionals
- Utilising external advisers for areas of complexity or specialism
- Involving, at an early stage, the Tax and Treasury Manager in all projects and commercial decisions in order to identify potential tax risk
- The JV Board taking an interest in, and recognising their responsibility for, managing material tax risks
- Keeping the tax liability projections of the JV Shareholders in relation to the Partnership under continual review
- Adopting an open and transparent relationship with HMRC to reduce uncertainty
Statement of Compliance
This publication is published in accordance with the obligations of Finance Act 2016 Schedule 19 “Large Businesses: Tax Strategies and Sanctions” s16(2) for the financial year ended 31 March 2023 and has been approved by the JV Board for that purpose. It is subject to review by the JV Board and will be periodically republished in accordance with the requirements of the Act.
Chief Financial Officer
The Arch Company Properties Limited, acting in its capacity of general partner of The Arch Company Properties L.P.
Date: 31 March 2023