Year Ended 31 December 2023
This document sets out our Tax Strategy as it relates to UK taxation, and satisfies the requirements of paragraph 16(2) of Schedule 19 Finance Act 2016.
It has been approved by our Board of Directors and constitutes our UK Tax Strategy statement for the fiscal year ended 31 December 2023. This Tax Strategy relates to the UK companies owned (directly or indirectly, in whole or part) by Union Maritime Limited.
We are a UK-based owner and operator of a modern fleet of tankers and bulk carriers. We pride ourselves on offering cutting-edge transportation and logistics solutions, leveraging the latest technologies and industry best practices to deliver unparalleled efficiency and reliability.
We have adopted an environmental, social, and governance (ESG) strategy that reflects our dual ambitions to be a global leader in sustainable shipping and to maintain the highest standards of corporate citizenship; by serving, protecting, and enhancing the communities in which we operate.
This Tax Strategy is aligned with the commitment in the governance limb of our ESG strategy to “conduct our business in accordance with the highest standards of governance and corporate citizenship, and in a way that enhances both our reputation in the market and the reputation of the wider shipping community.”
Specifically, as part of that governance imperative, we adhere to four principles:
- We have clear and robust management and reporting structures, designed to ensure rigorous and transparent application of policies across the organisation.
- We appreciate the critical importance of compliance with laws and regulations. We have a team of legal and compliance experts which monitors, analyses, and ensures adherence to relevant rules across our global activities.
- We maintain a comprehensive range of internal policies, designed to ensure the wellbeing and development of our people, and that they meet the high standards of business conduct.
- We are also exploring ways to help our counterparties and suppliers conduct their businesses responsibly.
Against that background, our Tax Strategy sets out our approach to management of our UK tax operations, including tax risk, tax planning, and engagement with tax authorities, including HMRC.
1. UK Tax Compliance and Reporting
We comply with all our UK tax filing, tax reporting, and tax payment obligations. This means we are committed to paying the right amount of tax required under UK laws and regulations, and we endeavour to interpret all applicable tax laws and regulations in accordance with the intentions of legislation and HMRC guidance.
In meeting these obligations, we apply diligent professional care and judgement, and ensure that there is sufficient evidence to support all judgements made in relation to UK tax compliance and reporting requirements.
2. Tax Risk Management and Tax Governance
Our Board is ultimately responsible for our UK Tax Strategy and supporting policies, with day-to-day tax management being delegated to our Finance Team. Where there are any significant tax risks, these are escalated by the Finance Team to the Managing Director and, where appropriate, to the Board.
We have a robust system of controls and processes in place to ensure risk is effectively managed in relation to our UK tax operations. This includes a system of internal controls including escalation and sign-off mechanisms in relation to tax payments and tax returns, reconciliation checks with underlying data and systems, and external support from independent tax advisors where specialist resource is required.
In addition, we undertake work on an annual basis with our external advisors in relation to the Senior Accounting Officer regime where we take a risk-based approach to review of our tax compliance processes and determination of how they support submission of accurate returns.
3. Tax Planning
We have a low-risk approach to management of our tax affairs, including tax planning. We seek to structure our tax affairs according to sound commercial principles and, wherever possible, we aim to have certainty of tax outcomes prior to entering into transactions.
We conduct cross-border transactions between group companies on an arm’s length basis in accordance with OECD principles.
Where appropriate, we utilise tax incentives and tax relief in accordance with the intentions for which they were introduced.
All tax decisions are aligned to our business and commercial strategy and are discussed as appropriate with our advisors.
4. Dealings with HMRC
We engage with HMRC regularly in a transparent manner and seek to maintain a strong, collaborative, and open relationship with them. This includes seeking input from HMRC in relation to tax issues of particular complexity and where there may be various interpretations of tax law. In all cases, we aim to supply information to HMRC as required, and on a timely basis.
We aim to work collaboratively with HMRC to achieve early agreement on challenging issues and to gain certainty on tax positions. We ensure we comply with all relevant legal disclosure requirements as required by the UK government and HMRC.