This Tax Strategy and Disclosure Statement applies to Kroll International UK Ltd and all its UK based subsidiaries, including Kroll Advisory Ltd, Duff & Phelps Securities Ltd, Trueform Trading Limited (UK), American Appraisal (UK) Ltd, Blackrock Expert Services UK Ltd, IT Group UK Ltd, Habermann Ilett UK Ltd, Redscan Cyber Securities Ltd, Redscan UK Ltd, Lucid Agency and Trustees Services Ltd, Lucid Issuer Services Ltd, Lucid Agency Services, Lucid Nominees Ltd, Lucid Trustee Ltd, Kroll Business Technology Ltd, Kroll Compliance Consulting LLP, Jester Topco Ltd, Jester Debtco Ltd, Jester Midco Ltd, Jester Bidco Ltd, Martello Top Co Ltd, Martello Global Ltd and Martello Bidco Ltd. It also includes other UK based entities of the Kroll group including Kroll Holdings Limited, Kroll Associates UK Limited and Kroll Information (UK) Ltd, together called the UK-based entities of Kroll (“Company”). Kroll regards this document as complying with its duty under Para (16)(2), Schedule 19 of the Finance Act 2016. This Statement covers Kroll's approach to the planning, execution, and disclosure of its tax matters.
Background
Delta Parent Holdings Inc. is the ultimate parent company of the private U.S.-based Kroll group that wholly owns Kroll International UK Ltd and all its UK based subsidiaries, including Kroll Advisory Ltd, Duff & Phelps Securities Ltd, Trueform Trading Limited (UK), American Appraisal (UK) Ltd, Blackrock Expert Services UK Ltd, IT Group UK Ltd, Habermann Ilett UK Ltd, Redscan Cyber Securities Ltd, Redscan UK Ltd, Lucid Agency and Trustees Services Ltd, Lucid Issuer Services Ltd, Lucid Agency Services, Lucid Nominees Ltd, Lucid Trustee Ltd, Kroll Business Technology Ltd, Kroll Compliance Consulting LLP, Jester Topco Ltd, Jester Debtco Ltd, Jester Midco Ltd, Jester Bidco Ltd, Martello Top Co Ltd, Martello Global Ltd and Martello Bidco Ltd. The group also includes other UK based entities of the Kroll group including Kroll Holdings Limited, Kroll Associates UK Limited and Kroll Information (UK) Ltd, together called the UK-based entities of Kroll and are collectively known as, the “Kroll UK Group”.
Commitment to Compliance
The Kroll UK Group is committed to complying with UK tax law. All members of the Kroll UK Group ensure that they pay all the tax they owe on a timely basis. The Kroll UK Group, in coordination with Kroll’s U.S. based Tax Department (“Kroll Tax”), also fully discloses all relevant facts and circumstances to the UK tax authorities and takes advantage of whatever relief and incentives are available and appropriate. This is achieved in the following ways:
- By ensuring that the group has a sizeable team of tax professionals to manage its tax affairs in a way that allows us to adequately respond to relevant tax risks.
- The group relies on reputable tax advisers to assist with tax compliance.
- The group always seeks external tax advice or clearance from tax authorities as needed, prior to undertaking significant transactions.
Positive Approach to Tax Planning
The group takes a proactive and prudent approach to tax planning. This is achieved by ensuring Kroll tax affairs are structured in a way that is compliant with all UK tax laws and employs tax law in a way that is sustainable for Kroll and all related stakeholders. Kroll seeks to deploy tax strategy that is value-added but is at the same time fully disclosed and transparent. Tax strategy is evaluated through a lens that ensures the Company is comfortable with the way a given strategy will look from every perspective.
Tax Risk Management and Governance
Kroll seeks to identify all significant tax risks as early as possible, and to monitor these risks over time, consistent with the Company’s tolerable level of risk. Risks are managed by ensuring that appropriate steps are taken, including but not limited to obtaining proper professional advice on complex transactions; ensuring that fact patterns are accurately depicted in any such advice; and being fully transparent with respect to complex transactions. To ensure all significant tax risks are appropriately disclosed and dealt with internally, corporate governance policies require all tax matters be referred to the Global Head of Tax, who, in carrying out governance policy, escalates tax risk matters to executive management and/or the Board as appropriate.
Relationship and Approach to HMRC
Kroll takes a thoroughly professional and forthright attitude in its dealings with Her Majesty's Revenue and Customs (HMRC). This begins with quality compliance, which includes full transparency in all matters, and securing professional advice where appropriate. All tax positions are thoroughly researched and documented to ensure they do not pose any significant tax or reputational risks to the Company.
Board Oversight and Ownership
This strategy was published in December 2022 and the Kroll UK Group regards this publication as complying with its duty under paragraph 16(2) Schedule 19 FA 2016 in its financial year ended December 31, 2022. This Statement covers Kroll’s approach to the planning, execution, and disclosure of its tax matters.