1. Purpose
This policy establishes Murzo Group’s governance framework for tax compliance and tax-related risk management.
Its objectives are to:
- Support accurate and timely compliance with applicable tax laws
- Ensure appropriate oversight of tax matters and related controls
- Reduce exposure to penalties, interest, disputes, and enforcement action
- Maintain robust financial records and auditability
- Provide a defensible framework for tax decision-making
This policy forms part of Murzo Group’s wider governance and risk management framework.
2. Scope
This policy applies to:
- Corporation tax and associated filings
- VAT and indirect taxes where applicable
- PAYE, National Insurance, and payroll-related obligations where applicable
- Customs duties and import/export tax liabilities where applicable
- Withholding taxes and cross-border tax issues where applicable
- All business units, operations, and transactions of Murzo Group
This policy applies globally and irrespective of jurisdiction.
3. Governance & Accountability
Murzo Group maintains accountability for tax compliance through:
- Appropriate management oversight
- Defined responsibilities for record-keeping and reporting
- Use of competent internal resources and, where appropriate, professional advisers
Where responsibilities are delegated, ultimate accountability remains with Murzo Group management.
4. Compliance Principles
Murzo Group’s approach to tax compliance is guided by the following principles:
- 4.1 Lawful Compliance: Murzo Group aims to comply with applicable tax laws and filing obligations in the jurisdictions where it is legally required to do so.
- 4.2 Accuracy & Reasonable Care: Murzo Group seeks to maintain accurate books and records and to apply reasonable care in tax decisions and filings.
- 4.3 Substance & Commercial Rationale: Murzo Group conducts transactions for genuine commercial reasons and not for artificial tax outcomes.
- 4.4 Proportionate Tax Risk Management: Tax risks are assessed and managed proportionately, taking into account the nature, size, and complexity of activities.
5. Tax Planning & Tax Risk Appetite
Murzo Group adopts a conservative approach to tax planning.
Murzo Group does not engage in:
- Artificial arrangements lacking commercial substance
- Schemes intended to conceal income or misrepresent transactions
- Transactions structured primarily to obtain tax advantages contrary to the intent of applicable law
Where uncertainty exists, Murzo Group may:
- Seek professional advice
- Adopt a prudent treatment
- Document assumptions and rationale
Murzo Group does not guarantee that tax authorities will agree with any particular treatment.
6. Use of Professional Advisers
Murzo Group may appoint professional advisers for:
- Tax returns, computations, and filings
- VAT and customs matters
- Employment tax and payroll issues
- Cross-border tax assessments and documentation
Use of advisers does not transfer legal responsibility away from Murzo Group.
7. Record-Keeping & Audit Trail
Murzo Group seeks to maintain adequate records to support tax compliance, which may include:
- Invoices, receipts, and contracts
- Payroll records
- VAT records and supporting documentation
- Bank statements and reconciliations
- Intercompany records (if applicable)
- Relevant correspondence and approvals
Records are retained in accordance with Murzo Group’s Records Retention & Legal Hold Policy (where adopted) and applicable law.
8. Confidentiality & Disclosure to Authorities
Murzo Group treats tax and financial records as confidential.
Murzo Group will:
- Preserve confidentiality of its business records
- Disclose information to tax authorities only where required by law, valid legal process, or binding statutory obligation
- Respond to lawful information requests through controlled internal processes
Murzo Group does not make voluntary disclosures or provide access beyond legal requirements.
Nothing in this policy limits Murzo Group’s right to seek legal advice, assert legal privilege, or challenge overbroad or improper requests.
9. Queries, Enquiries & Investigations
If approached by a tax authority:
- Murzo Group may verify the validity and scope of any request
- Responses are coordinated internally and may be handled through legal or professional advisers
- Access to records is restricted to what is lawfully required
Murzo Group may contest requests that are unclear, excessive, or not properly authorised, protect privileged or confidential information, and manage communication through designated representatives.
10. Internal Controls & Fraud Prevention
Murzo Group seeks to apply proportionate internal controls designed to reduce tax and financial risk, including:
- Segregation of duties where practicable
- Approval processes for payments and expenses
- Reconciliation and review procedures
- Measures to prevent fraud, misstatement, or misuse of funds
This policy operates alongside Murzo Group’s Anti-Fraud and Financial Misconduct controls (where adopted).
11. International & Cross-Border Considerations
Where Murzo Group engages in cross-border activity, it may consider:
- Tax residence and permanent establishment risk
- Withholding obligations
- VAT and customs implications
- Documentation requirements
- Local filing triggers
Murzo Group may restrict, restructure, or withdraw from international activity where tax risk is unacceptable.
12. Non-Compliance & Corrective Action
Where errors or non-compliance are identified, Murzo Group may investigate the cause, correct records or filings where appropriate, implement corrective controls, and obtain professional advice.
Murzo Group does not admit liability or wrongdoing by implementing corrective measures.
13. Legal Position & Limitations
This policy does not constitute tax or legal advice, does not create contractual obligations, does not guarantee tax outcomes or authority acceptance, and does not waive Murzo Group’s legal rights or privileges.
Nothing in this policy excludes liability that cannot be lawfully excluded.
14. Review & Updates
This policy is reviewed periodically and may be updated to reflect changes in law or guidance, operational growth and international expansion, and lessons learned from audits or reviews.
