Thirteen Housing Group Limited and its subsidiaries which form the “Thirteen Group” are not subject to the Senior Accounting Officer (SAO) Rules or required by law to publish a tax strategy.
Nevertheless, we voluntarily seek to ensure compliance with SAO rules as matter of best practice, consistent with HMRC’s 2016 guidance, and we have a tax strategy.
What is a tax strategy?
A tax strategy is a document that clearly sets out:
- How we manage UK tax risks
- Our attitude to tax planning
- The level of risk we are prepared to accept for UK taxation
- How we work with HMRC
- Any other relevant information relating to taxation
Below is our tax strategy statement, which presents a clear and simple summary of our detailed tax strategy for Thirteen customers. Our detailed tax strategy, which we use for internal purposes, is reviewed by our Finance Committee and must be approved by our board. This is not published as it is commercially sensitive.
The statement is presented in compliance with Section 161 and paragraph 16(2) Schedule 19 of Finance Act 2016 in respect of the year ending 31 March 2026 and is approved by our board.
Our tax strategy
Who are Thirteen?
- We own and manage over 36,000 homes across the England’s North East, Yorkshire and Humber regions.
- As well as managing homes, we offer various wrap around services which benefit our tenants and helps maintain people’s health, security and happiness.
- We offer homes for affordable and social rent, shared ownership and supported and sheltered housing. We continue to complete a small number of outright market sale properties through our subsidiary Thirteen Homes.
- Some of the latest developments and/or acquisition of new homes are offered to tenants under new leases which give the tenant the right to convert a rented property to shared ownership (RtSO).
- The Thirteen Group’s group structure consists of a parent company, which is registered with HMRC as a charitable entity, and multiple subsidiary companies which help to achieve the group’s objectives.
- All of Thirteen Group’s profits and gains, regardless of which entity they are generated in, are used for the benefit of the group and its objectives. Profits are reinvested back into homes, our services and into brand new homes. Thirteen does not have any shareholders, it is a Community Benefit Society existing for the benefit of the community.
How do we manage our tax risks?
- We manage our tax risks by employing people that have responsibility for tax compliance, having robust controls in place and maintaining a risk register.
- Our Chief Resources Officer has overall responsibility for tax compliance and delegates day to day management of taxes to staff in our resources teams.
- Our Finance Committee reviews our tax strategy every three years before recommending that it is approved by our board. Our board is required to approve a tax statement for each financial year. This is in line with HMRC guidance.
- We consider tax as part of our day-to-day operations. The needs of our business do not override compliance with the applicable tax legislation. We recognise there might be times when there could be a trade-off between commercial gain and tax efficiency but always endeavour to structure transactions that deliver the best value for money for the group.
- We require the members of the finance team responsible for accounting for tax to hold suitable qualifications and encourage them to undertake relevant training and keep up to date through professional development.
- The detailed tax strategy is available on Thirteen’s intranet for internal use only and is not published as it is commercially sensitive.
What is our attitude to tax planning?
- Thirteen Housing Group Limited is recognised by HMRC as a charity for tax purposes and does not undertake aggressive tax planning.
- We document all tax risks in a risk register that is maintained and reviewed regularly.
- We document tax risks relating to material transactions, such as a new development of social housing, as part of the approval process.
- Where it is considered there is a tax uncertainty or insufficient internal expertise, we will seek external expertise to assess tax risks and compliance.
- We give due consideration to our reputation, brand, and corporate and social responsibilities when considering tax planning.
What is our attitude to tax risk?
- We operate a low-risk, cautious approach to tax and our tax strategy is aligned to this attitude as we recognise that tax can have a significant impact on our reputation and financial results.
- We endeavour to be as tax efficient as possible when conducting transactions and we consider the tax impact as part of the approval process for new homes development, new business opportunities and investment in existing homes.
- Our employees are encouraged to discuss the tax position in the early stages of any transaction so the tax impact can be understood and mitigation measures explored as appropriate.
- We have an agreed escalation process for the effective operation of the group’s tax affairs, with ultimate oversight by our board.
- We believe in paying the right amount of tax at the right time – we only engage in cautious tax planning and do not participate in any tax avoidance schemes.
- We have a tax risk register, which is kept updated and is supported by multiple controls throughout the business to manage our daily tax affairs.
- An external audit is carried out by a leading accountancy firm every year, and our tax reporting and balances are scrutinised as part of this.
- We have access to external advisors who can provide tax advice as required. The advisors are a leading accountancy firm, separate to the auditors, and work closely with us and our appointed external solicitors as required.
- We do not operate outside the UK so are only governed by UK legislation which we abide by.
- We retain records and documents used to prepare tax returns for the periods prescribed in the Finance Act – six years from the end of the accounting period.
How do we conduct our relationship with HMRC?
- We believe in having a collaborative, positive and transparent working relationship with HMRC.
- By reporting our taxes on time, dealing with our taxes in a controlled manner with appropriate oversight, and employing suitably qualified employees, we aim to be considered low risk by HMRC.
- Where any inadvertent errors are identified, we disclose them to HMRC in a proactive manner, then rectify and pay any associated penalties and interest as quickly as possible.