Cubico Group Tax Policy
Financial Year Ended 31 December 2018

This policy applies to Cubico Sustainable Investments Holding Limited (‘Cubico’) and all the entities in its group.

Our tax policy comprises five key components:

1.         Commitment to compliance

Cubico is committed to compliance with tax law and practice globally. Our interpretation of compliance means paying the right amount of tax in the right place at the right time. It involves disclosing all relevant facts and circumstances to the tax authorities and claiming reliefs and incentives where available.

In the UK, preparation of our corporate tax returns is outsourced to a reputable top 10 accounting firm. A multinational payroll provider performs payroll tax compliance. VAT returns are substantially prepared by our in-house finance function. Consequently, substantially all our UK tax returns are prepared independently of the group finance function, except for VAT.

2.         Responsible attitude to arranging our tax affairs

In structuring our commercial activities we will consider - among other factors – the tax laws of the countries in which we operate, with a view to maximising value on a sustainable basis for our shareholders and employees.  For example, we will look to take steps to reduce the risk of double taxation (i.e. the same income being taxed twice in two different jurisdictions).  Any structuring which is undertaken will have commercial and economic substance and will have full regard to the potential impact on our reputation and that of our shareholders.  We will not put in place any arrangements which are contrived or artificial.

3.         Effective risk management

The business of the Cubico group consists of owning and developing renewable energy projects and investing in projects on a worldwide basis.  Risks will inevitably arise from time to time in relation to the interpretation of relatively complex tax law.  We actively seek to identify, evaluate, monitor and manage these risks to ensure they remain in line with our objectives. Where there is significant uncertainty or complexity in relation to a risk, external advice is regularly sought, particularly in relation to transactions buying or selling projects. 

4.         Constructive approach to engaging with tax authorities

We engage with tax authorities worldwide with honesty, integrity, respect and fairness and in a spirit of co-operative compliance. Wherever possible, we do so on a real time basis, to minimise tax risk. Whilst we will not take positions on tax matters that may create reputational risk or jeopardise our good standing with taxing authorities, we are however prepared to litigate where we disagree with a ruling or decision of a tax authority, having always first sought to resolve any disputed matters through active and transparent discussion. 

5.         Board ownership and oversight

This tax policy is aligned with the Cubico General Code of Conduct, in particular Chapters IX and X.  This policy is approved and owned by the Executive and overseen by the Board.  Cubico Sustainable Investments Holdings Limited regards this publication as complying with the duty under para 16(2) and para 25(1), Sch 19 FA16.