Introduction
This document sets out the University of Bath’s approach to managing its tax affairs and associated risks. It has been prepared both to fulfil HMRC (His Majesty’s Revenue and Customs) expectations for organisations to implement a Tax Strategy and as a matter of best practice for the University. The University of Bath is required to publish a tax strategy in accordance with Para 16(2) of Schedule 19 to the Finance Act 2016.
The document is owned by the Finance and Procurement Office (F&PO) and will be reviewed annually by the Director of Finance and any amendments will be approved by the Finance Committee.
This document sets out the University’s:
Approach to risk management and governance arrangements for tax
Attitude towards tax planning
Level of acceptable risk in relation to taxation
Approach to dealings with HMRC and the equivalent regulators in overseas jurisdictions
Approach to working with professional advisors
Approach to supporting best practice in tax affairs across the UK Higher Education sector.
Approach to risk management and governance arrangements
In accordance with the University’s Statutes and Ordinances, the Council of the University of Bath is responsible for the administration and management of the affairs of the University. Council comprises a number of ex-officio, appointed and elected lay and academic persons, the majority of whom are non-executive. Authority is delegated to key executives for day-to day operation of the University’s affairs in accordance with an agreed schedule of delegation. A number of Committees report to Council in key areas, usually four times per annum. The University’s tax affairs are the responsibility of the Finance Committee.
The Audit & Risk Assurance Committee has responsibility for overseeing the University’s overall risk management and systems of internal control.
The ultimate responsibility for day-to-day operation of the University’s tax affairs rests with the Director of Finance. The Director of Finance Operations has day-to day authority to manage the tax affairs of the University assisted by the Tax Specialist and members of the Financial Accounts Team.
The Tax Specialist and most of the Financial Accounts Team are qualified accountants. The University supports them in developing and keeping their knowledge up to date through Continuous Professional Development.
The Tax Specialist and Financial Accounts Team uses various risk management processes and controls to provide assurance that the requirements of the University Tax Strategy are being met. This includes compliance and risk monitoring processes and internal reviews of tax compliance activity across the University. The team gives business partner support across the University to provide advice and training on a timely basis.
Tax Planning
The University will use available incentives and reliefs to minimise the tax cost of conducting its activities to retain more funds to further its charitable objectives.
The University intends to pay any tax charge that is legally due. Where this amount is not clearly defined, or where alternative interpretations or approaches might result in different tax outcomes, the University will use its best judgement to determine the appropriate course of action. This will usually involve seeking advice from external professional advisers and/or Tax Counsel.
The University will not enter into transactions that have a main purpose of gaining a tax advantage or intentionally make interpretations of tax law that are opposed to the original intentions of the legislation.
Level of acceptable risk
The University’s appetite for risk in any activity is determined by Council. The appetite for tax risk is consistent with the approach to tax planning identified above.
Working with HMRC and other regulators
The University favours a transparent and positive relationship with HMRC and other tax and social security regulators outside the UK. We will work with them in an open and professional manner, responding to enquiries and consultations in a timely fashion and proactively approaching any regulator when appropriate.
Working with other bodies
The University engages professional advisors to support its tax planning and compliance. It also approaches professional providers for training support and to supplement in house expertise.
Additionally, the University is an active member of the British Universities Finance Directors Group (BUFDG) community, which promotes best practice across the sector and the University participates in charitable and accountancy body networking and similar activities.
Report to Finance Committee
The Director of Finance Operations will provide an annual report to Finance Committee summarising the activities undertaken in the year and including details of any errors identified, penalties and or interest incurred as a result of tax errors or omissions either identified by the University or HMRC or other regulator in excess of £5k for any single instance.
Approved by Finance Committee in June 2019 (FC 17/18 – 049)
Updated June 2022 to include regulators outside the UK
Updated June 2025 to include the new Tax Specialist role