UK tax strategy – 2022
Engelhart (formerly known as BTG Pactual Commodities) was established in 2013 and is a global diversified financial and physical commodity trading company transacting across a range of commodity products and portfolios. The group is headquartered in London and operates in global platforms throughout our network of offices.
We primarily focus on financial trading supported and enhanced by our sophisticated research, market analytics, proprietary systems and risk management with a goal of leading market performance across our trading portfolio via capturing market opportunities through market price inefficiencies while mitigating key stress factors. In our physical commodity business, we operate in segments of the value chain and our approach to tax supports our business to ensure timely and accurate compliance with all of our tax obligations.
This UK tax strategy is published in compliance with paragraph 19(2) Schedule 19 Finance Act 2016 for year ending 31 December 2022 and applies to Engelhart CTP Group (UK) Limited and all direct and indirectly owned entities within the UK group.
Governance and risk management
The Chief Financial Officer is responsible for this UK tax strategy which has been reviewed and approved by the Engelhart Management Committee. The Chief Financial Officer delegates the implementation of the UK tax strategy to the Head of Tax and delivery of the strategy is supported by the group tax and finance teams. The UK tax strategy is reviewed on a regular basis and any changes are approved by the Engelhart Management Committee.
The Engelhart risk management framework requires that, in addition to being guided by the highest ethical standards and our own strict in-house compliance rules, we also adhere to international-standard governance procedures. We have therefore implemented procedures, processes and frameworks to manage tax risks and mitigate the impact of material risks on our business.
We are committed to complying with all relevant tax laws, rules, regulations and practices in the UK and all the territories in which we operate, and to pay the amounts of tax legally due. As part of our monthly financial reporting cycle, the group tax team assesses any tax risks arising (including those reported by our operations teams) and notifies any material risks to the Chief Financial Officer, Engelhart Management Committee and (in appropriate cases) Engelhart risk management committees.
We periodically review how we meet our tax obligations by seeking external tax advice, investing in training for our staff and reviewing our processes and framework to address new and emerging risks.
Engelhart undertakes tax planning as part of our overall strategy to strengthen our business and optimise returns to our shareholders.
The tax costs/risks of key business decisions are proactively assessed, and professional advice is sought to secure certainty and mitigate risks/disputes. The extent of such professional advice is driven by our assessment of the risk presented by each opportunity.
Engelhart does not undertake aggressive tax planning, the sole purpose for which would be obtaining a tax advantage. However, we will make use of such tax incentives, exemptions and reliefs provided in law to minimise the tax costs to our business.
Attitude towards risk
Engelhart Management Committee sees compliance with tax legislation as key to managing our tax risk. As a group, we understand the importance of tax in the wider context of business decisions and have processes in place to ensure tax is considered as part of our decision making process.
We are not prescriptive about the level of tax risk which is acceptable. Our approach is to ensure we are compliant and understand our responsibilities with regards to tax, rather than looking for ways to aggressively avoid payment of tax. Where there is material uncertainty concerning the appropriate treatment of a transaction, we would normally only proceed on the basis of advice from our professional advisers that the transaction in question ought to have the particular outcome. We have relationships with professional advisers that allow us to seek expert advice on specialist areas of tax both in the UK and abroad.
Relationship with HM Revenue & Customs (‘HMRC’)
Engelhart is committed to working collaboratively with HMRC to promote an open, transparent and trust-based relationship.
We are focused on timely tax compliance and endeavour to meet all relevant filing and payment deadlines for each group company. We work with our professional tax advisers to make fair, accurate and timely disclosures in our tax returns and are committed to working with HMRC to resolve any disagreements on interpretation of tax laws, in a reasonable way.
Published: January 2022