Cubico Group Tax Policy
Financial Year Ending 31 December 2024
This policy applies to Cubico Sustainable Investments Holdings 1, LP (‘Cubico’) and all group entities globally.
Cubico recognises our duty to comply with tax legislation and uphold the principles of good corporate citizenship and is committed to upholding the highest standards of ethical conduct in its tax practices. As a responsible corporate citizen, it is committed to contributing positively to the communities and economies in which it operates. This Group Tax Policy outlines its approach to tax compliance and commitment to conducting its tax affairs with integrity, transparency and accountability.
Cubico recognises that paying taxes is a fundamental responsibility of doing business, and is committed to fulfilling this responsibility in a manner that reflects its values and contributes positively to society.
Cubico has two full-time tax professionals based in the London office and another tax and accounting manager in Mexico. In other countries of operation, tax is managed through a combination of in-house and external resource, with the UK based Head of Tax and Senior Tax Manager retaining oversight and sign-off.
Cubico’s tax policy comprises five key components:
- Commitment to compliance
Cubico is committed to compliance with all applicable tax laws, regulations and reporting requirements globally. Tax planning and reporting is conducted in accordance with the spirit as well as the letter of the law.
Cubico’s interpretation of compliance means paying the right amount of tax in the right place at the right time. Cubico seeks to adhere to all reporting obligations whilst disclosing all relevant facts and circumstances to the tax authorities, including details of any reliefs and incentives claimed.
In respect of corporate taxes, in all countries tax returns are prepared and reviewed by tax professionals with the relevant local knowledge and experience. This can vary from a fully in-house tax compliance process in the UK to a fully outsourced model in Colombia. When outsourced there is an appropriate internal review of the tax returns prior to submission.
In respect of other taxes:
- A multinational payroll provider performs payroll tax compliance globally;
- Indirect tax returns are prepared or reviewed by experienced professionals. These may be in-house or external.
In the UK, the tax controls are reviewed by internal audit each year as part of the Senior Accounting Officer report. In other countries, internal audit review the tax controls as part of their regular review of the local financial controls.
Where required, external advice is obtained to ensure Cubico’s obligations are met in all countries of operation.
- Responsible attitude to arranging our tax affairs
In structuring its commercial activities, Cubico considers, among other factors, the tax laws of the countries in which Cubico operates. These tax laws are continually changing and are often open to interpretation. Cubico is prudent in its approach to tax law whilst maximising value on a sustainable basis for investors and employees. For example, Cubico takes steps to reduce the risk of double taxation (i.e. the same income being taxed twice in two different jurisdictions).
Cubico’s overall group structure and any structuring which is undertaken (such as for acquisitions or divestments) always has commercial and economic substance and does not involve any arrangements that are contrived or artificial. In respect of its tax policy, Cubico has full regard to the potential impact on its reputation and that of its investors.
- Effective risk management
The business of the Cubico group consists of owning and developing renewable energy projects and energy infrastructure. Cubico invests in projects on a worldwide basis. Risks inevitably arise in relation to the interpretation of complex tax law. Cubico actively seeks to identify, evaluate, monitor, and manage these risks to ensure they remain in line with its objectives. Where there is significant uncertainty or complexity in relation to a risk, external advice is regularly sought, particularly in relation to acquisitions and disposals of assets. Cubico maintains appropriate documentation to support its tax filings and positions.
Cubico provides regular training and education to its employees involved in tax related matters to ensure they understand their responsibilities and obligations under this Group Tax Policy. Cubico fosters a culture of compliance and integrity throughout the organisation, encouraging open communication and adherence to its principles.
Cubico continuously reviews and monitors its tax policies, procedures and practices regularly to ensure that they remain effective and compliant with applicable laws and regulations. Cubico also assesses emerging tax developments and changes in tax legislation and adapts the tax strategy accordingly.
- Constructive approach to engaging with tax authorities
Cubico engages with tax authorities worldwide with honesty, integrity, respect and fairness and in a spirit of co-operation to resolve any disputes or queries which may arise. Cubico is committed to building constructive and collaborative relationships with tax authorities in all jurisdictions where the group operates. Wherever possible, it does so on a real time basis to minimise tax risk and uncertainty. Cubico does not take positions on tax matters that may create reputational risk or jeopardise its good standing with taxing authorities.
Cubico believes in transparency and provides clear and comprehensive disclosure of its tax affairs to the relevant tax authorities. It also discloses relevant tax information to stakeholders, including investors, regulators, and to the public, to the extent permitted by law and consistent with its obligations to protect sensitive commercial information.
- Board ownership and oversight
The Head of Tax meets regularly with the Chief Finance Officer to discuss the Group’s tax affairs and updates the Audit and Risk Committee of the Board annually.
This tax policy is aligned with the Cubico General Code of Conduct, in particular Chapters IX and X.
This policy is approved by the Audit and Risk Committee of the Board.
Cubico Sustainable Investments Holdings 1, LP regards this publication as complying with the duty under para 16(2) and para 25(1), Sch 19 FA16.
