Resolution Life - UK Tax Strategy

This document sets out our strategy in relation to UK taxation for the Resolution Life Group Services Limited (RLGS) sub-group and Resolution Life UK Holdings Limited (RLUKH) (collectively, the UK Entities).

Resolution Life is a global life insurance group focusing on the acquisition and management of portfolios of life insurance policies, with operating companies based in Bermuda, Australia/New Zealand and the US.

The group has a UK subsidiary, RLGS, which provides services to group entities.  RLGS is the parent company of a small sub-group in the UK (the RLGS sub-group), as well as a small Canadian company. The group also has a UK holding company, RLUKH, which is the holding company of a foreign sub-group.

Approach to risk management and governance arrangements

The Group Chief Financial Officer and Group Chief Risk Officer both work for RLGS and, alongside the Group’s Executive Committee and Board, are committed to ensuring that the tax function manages risk effectively.  The tax function is represented on the Group Finance Committee, which reports to the Executive Committee.

Approach to tax planning in relation to UK taxation

It is the intention of the UK Entities to comply with the tax legislation and regulations applicable in the UK, and to pay taxes accordingly.

In relation to the UK Entities’ approach to tax planning:

  • We do continuously review our legal and operating structure to ensure that it operates efficiently from a capital, regulatory and tax perspective;
  • Where we are undertaking transactions or projects, we do seek to carry them out in a tax efficient manner, consulting with our internal tax function and our external tax advisers where necessary;
  • We do consider the features of jurisdictions’ tax regimes, including the UK, when making business decisions (this is always balanced with commercial, regulatory and legal aspects);

But:

  • We do not intentionally take tax positions which are likely to be regarded by the UK tax authorities as aggressive or egregious.

Level of risk accepted in relation to UK taxation

The UK Entities’ intention is to comply with the relevant tax law and pay our taxes accordingly.  Our tax compliance obligations are a priority, and our intention is to have a low tolerance for error or for late submissions.

Tax risk can arise from the combination of the complexity of the group and its acquisitions.  We have sought to reduce and manage such risk by establishing an internal tax function, and by seeking external consultancy support where appropriate.

Approach to dealings with HMRC

Our intention is to have an open and transparent relationship with HMRC, and to deal with any enquiries in a timely and courteous way.

This document is published in accordance with paragraph 16(2) of Schedule 19 of Finance Act 2016 for the year ended 31 December 2023 with the approval of the RLGS and RLUKH Boards of Directors.