This document outlines the tax strategy for Kelly (UK) Limited (the “Parent”) and its UK directly owned subsidiaries – Kelly Payroll Services Limited and Toner Graham Limited (the “UK subgroup”) (the Parent and UK subgroup, collectively the “Company”). The Parent is a wholly owned indirect subsidiary of Kelly, Inc. (“KSI”), whose principal place of business is in Troy, Michigan USA. The Company adheres to all KSI global policies and procedures.
KSI’s vision is to be the most creative, insightful and agile talent company, committed to uniting vital talent with great organisations where KSI thrives. As outlined in KSI’s global Code of Business Conduct and Ethics, the Company is committed to doing the right thing, conducting itself in a legal, ethical and trustworthy manner, and upholding its regulatory obligations in each of the countries where it operates.
The purpose of this statement is to satisfy the UK legislative requirements of Paragraph 19 of Schedule 19 of the Finance Act 2016. This Tax Strategy applies to the fiscal year
ending December 2020.
This Tax Strategy is communicated to all the relevant stakeholders at the Company, from the management who are making regular commercial decisions to those individuals who are involved in the daily tax processes and procedures that the Company operates. This strategy has been approved by each entity’s board of directors (collectively the “Board”) and KSI’s global tax
Overall Tax Strategy
The Company is committed to full compliance with all statutory obligations and full disclosure to relevant tax authorities. The Company’s tax affairs are managed in a way which takes into account its wider corporate reputation and overall high standards of governance.
How the Company manages UK tax risks
The Company has established and maintains appropriate tax accounting arrangements and strong internal controls to manage its tax risk including:
The Board has ultimate responsibility for the tax strategy and tax compliance.
The Company’s Board delegates responsibility for tax matters to the Company’s management team.
The UK Finance Director has day-to-day responsibility for UK taxation including the filing of returns and remittance of taxes, supported by external advisors. Key risks and issues related to UK taxation are discussed with KSI’s global tax department.
The Company is staffed with appropriately qualified individuals.
The Company reviews its tax compliance processes on an ongoing basis.
The Board understands the importance of and its obligations towards tax compliance.
There is ongoing dialogue between the Board and the finance function in relation to tax matters.
The Company’s attitude to tax planning
Tax planning by the Company is aligned with its commercial objectives and complies with applicable UK tax rules and regulations and is intended to support our corporate and social responsibilities and not negatively impact the Company’s reputation or brand.
The Company’s intercompany transfer pricing policies and all intercompany transactions are based on the “arm’s length principle” and are in accordance with UK legislation and OECD principles. The UK subgroup consults with external advisors as needed to ensure compliance with all applicable rules and regulations.
The Company and its level of acceptable tax risks in the UK
The Company recognises our responsibility to conduct ourselves in a legal and ethical manner as discussed in KSI’s global Code of Business Conduct and Ethics. The Company accepts risk that is carefully considered, within our tolerance, and will not tolerate activity that endangers our employees or others, jeopardises our financial well-being, or is contrary to our character and values. The Company manages all tax risk with professional diligence, while respecting the laws and regulations that govern our business and ensuring that governance procedures are appropriate.
Working with HMRC
The Company is committed to the timely filing of its tax returns. The Company will comply with all relevant legal disclosure and approval requirements and all information will be clearly presented to HMRC as appropriate. The Company will work with HMRC to resolve any issues in a timely, professional and respectful manner through open, honest and transparent discussions.