Sompo Japan Nipponkoa Insurance Company of Europe Limited (“the Company”) is a member of the Sompo Holdings Group (“the Group”).  This document sets out the Company’s tax strategy in accordance with paragraph 22 of Schedule 19 to the Finance Act 2016.  

Our approach to UK tax risk management and risk appetite

For all actions, our Group is committed to:

  • Act in the knowledge that our every action as an individual shapes our entire reputation as a company;
  • Act with initiative, set ourselves the highest goals, and always learn from our actions;
  • Strive to be both prompt and clear in our dealings and activities; and
  • Act with the utmost integrity.
We seek to ensure that our approach to all UK tax compliance matters is aligned with these Group principles. We seek to act with integrity and responsibly.   We are committed to fully complying with all tax laws, rules, and regulations which apply to us without exception.  We aim to be efficient in our tax affairs but tax mitigation is not a driver for activity.
Tax planning opportunities arising from commercial transactions will be considered by the Board to ensure a beneficial post-tax result of any transaction.


We believe that tax risk should be prudently managed and controlled.   The Company is not prescriptive in terms of the level of acceptable tax risk and each matter is assessed on its specific facts and circumstances. We consider ourselves to have a prudent risk appetite and low risk tolerance. We operate within an effective tax control framework focussing on risk identification, control activities and effective channels of communication. We monitor the impact of relevant external tax law developments and internal business initiatives on our tax compliance and reporting obligations.
The Company’s framework governing tax risks is described below:

  • The Company’s  Board has ultimate responsibility for the tax strategy;
  • The executive management of the Company is delegated to the Executive Committee, including the management of its tax affairs;
  • The Chief Financial Officer has executive responsibility for tax matters and holds the role of Senior Accounting Officer (“SAO”);
  • The day-to-day management of the Company’s tax affairs  is carried out by managers within the Finance and HR departments;
UK tax reporting and compliance is also periodically reviewed by our Internal Audit function in connection with our UK Criminal Finance Act compliance procedures and our UK SAO accounting procedures.

Where the tax law is unclear or subject to interpretation, we engage external tax consultants for tax compliance and advisory assistance as an additional safeguard to ensure tax compliance and reduce tax risks.

Our approach towards working with tax authorities including HMRC

We recognise that the tax authorities in the various jurisidictions in which we do business play an important role. We believe that a mutually open and transparent relationship is essential for creating long-term shareholder value.

We seek to maintain an open, transparent and constructive relationship with HM Revenue and Customs (“HMRC”). We respond to all HMRC queries in a transparent, complete and timely manner.

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