This document sets out the tax strategy pertaining to UK taxation for Phillips 66 with the information required by Part 2 of Schedule 19 to Finance Act 2016.
Phillips 66 has two UK sub-groups which are required to publish a UK tax strategy. The parent companies of these two sub-groups are Phillips 66 UK Holdings Limited and Phillips 66 European Power Limited respectively, and this UK tax strategy document is published jointly by these two companies. This UK tax strategy has been approved by the boards of directors of Phillips 66 UK Holdings Limited and Phillips 66 European Power Limited. It applies from the date of publication noted below until superseded or updated.
All applicable entities in the Phillips 66 UK Holdings Limited and Phillips 66 European Power Limited sub-groups at the date of publication to which this UK tax strategy applies (hereafter jointly referred to as the "Group") are listed in the Appendix below.
Management & Governance
Tax is an important component in the business dealings of the Group. The Group takes its tax compliance responsibilities seriously, and seeks to be compliant with tax legislation.
Accountability for the Group’s tax affairs resides with UK executive management, with responsibility delegated to the Manager, UK Tax, who in turn leads an in-house specialist tax team with extensive knowledge and experience across all major UK taxes.
A number of key business, tax and other financial processes are in place, administered under a philosophy of strong controls on areas that include project approvals, reporting transparency and accuracy, and integrity and ethics. The Group is subject to the senior accounting officer rules, which require a senior employee of the Group personally to oversee UK tax compliance.
The Group’s senior accounting officer and its UK tax manager are both members of the boards of directors of each of the Group’s active trading and holding companies. The Tax function is therefore well-placed to be aware of significant transactions or issues, and tax matters have appropriate interest and visibility at UK board level.
Tax planning by the Group is focused on ensuring its wider business and commercial activities are tax efficient, with utilization where appropriate, of available and intended legislative incentives, exemptions and reliefs. The Group strives to be a responsible corporate citizen, and does not seek to engage in artificial or contrived tax avoidance outside the intentions of Parliament where they are understood.
The Group seeks to avoid material uncertainty or exposure to risk on tax liabilities. The Group will engage with HMRC on complex or specialist areas, and where matters of uncertainty arise or where HMRC may interpret legislation differently, the Group may take external professional advice. Significant or potentially contentious matters are discussed in advance with executive UK management, and where appropriate, senior management of the Group’s US parent company, before any action is taken.
Dealings with HMRC
The Group enjoys an open and transparent relationship with HMRC, and adopts an approach of full disclosure in all communications with HMRC, including return filings. Potential issues or areas of uncertainty or contention are openly and timely raised with HMRC. Frequent, two-way communication with the Group’s HMRC Customer Compliance Manager and subject matter expert Tax Inspectors occurs to address areas of policy or uncertainty of treatment, and to ensure accuracy and full disclosure in return filings.
Date published: 19 December 2017
Appendix to UK Tax Strategy
Phillips 66 UK Holdings Limited & UK subsidiaries:Phillips 66 European Power Limited & UK subsidiary:
Phillips 66 UK Holdings Limited
Phillips 66 Limited
Phillips 66 Treasury Limited
Phillips 66 Trading Limited
Phillips 66 TS Limited
Phillips 66 Pension Plan Trustee Limited
Phillips 66 UK Funding Limited
Phillips 66 CS Limited
Jet Petroleum Limited
JET Petrol Limited
Phillips 66 European Power Limited
Phillips 66 UK Development Limited