Strategy

The Bank is fully committed to full compliance with all statutory obligations and full disclosure to tax authorities, which includes reporting to relevant tax authorities in accordance with appropriate requirements and standards. The Bank’s tax affairs are managed to take into account its wider reputation and in line with its high corporate governance standards.

The Bank is committed to pay the appropriate amount of tax due in the UK according to relevant tax rules and legislation.

Tax is accounted for in accordance with respective rules and regulations in an accurate and timely manner. Any issues that may subsequently arise are dealt with in an open and proactive way with HM Revenue & Customs (HMRC). 

Risk Appetite

Whilst the Bank seeks to reduce the level of tax risk arising from its operations in London as far as reasonably practicable and in line with respective rules, our appetite for any tax risk is low and we seek to manage this via open dialogue with HMRC and by seeking professional guidance as required to ensure we fully comply with all obligations.

ANB will only undertake tax planning in the context of wider business activities having a commercial and economic basis.

The Bank does not provide tax advice to its clients and whilst it will make payments of tax to the UK authorities on their behalf (based on their instructions) the Bank cannot be held responsible if any such tax owed by them is not made. The Bank has no tolerance for any tax avoidance, deliberate or otherwise, and has a sufficient suit of policies, procedures and awareness to relevant client-facing staff commensurate with the level of tax risk.

Roles and Responsibilities

The London Branch Financial Controller has overall responsibility for the execution of the strategy and any submissions to HMRC or other tax authorities, assisted where required by the London Branch General Manager. All records are held in London Branch for review and inspection by HMRC or the Bank’s internal or external auditors, in accordance with statutory time limits and/or its internal data retention policy. The London Branch of ANB may also use professional tax advisors, where required, to ensure full compliance with all aspects of this strategy and adherence to technical rules issued by HMRC.

The Bank is committed to comply with all laws, rules and regulations of relevant legislative bodies and financial regulators in all jurisdictions in which it operates. Oversight is achieved through a robust Corporate Governance Framework.

Relationship with HMRC in the UK 

In the UK, the Bank seeks to have a fully transparent and constructive relationship with HMRC, which can be via regular communication/correspondence or via calls/meetings in respect of any developments in the Bank’s business and current/future or retrospective tax matters. As part of this ongoing obligation the London Branch of ANB adopted Section 1 of the HMRC Code of Practice on Taxation for Banks in September 2010.

The Bank ensures all tax returns are submitted to HMRC in complete form and include all relevant facts and aims to ensure HMRC are kept aware of significant changes in its business and any possible tax implications at an early stage. Any inadvertent errors in submissions made to HMRC are fully disclosed as soon as reasonably practicable after they are identified.