Tax Strategy for the United Kingdom
This document sets out Evercore’s approach and strategy for handling its tax affairs and managing the tax risks for the year ending 31 December 2018 of all entities listed below (each an “Evercore UK entity”, and together “Evercore UK”)
Evercore UK regards the publication of this tax strategy as complying with section 161 and paragraphs 19(2) and 22(2) of Schedule 19 to the Finance Act 2016. It applies to each Evercore UK entity and applicable UK taxes.
This strategy is reviewed and updated annually. It is approved by the boards of directors of Evercore UK.
Evercore is a global independent investment banking advisory firm dedicated to the highest calibre of professionalism. The Evercore UK entities are majority owned by Evercore Inc., a US publicly traded company listed on the New York Stock Exchange. Evercore UK’s tax strategy is based on policies, procedures and controls that are compliant with all applicable UK tax legislation. We seek to ensure that we pay the appropriate amount of UK tax, and that UK tax returns and payments are accurate and made on time.
Risk management and governance arrangements
Evercore UK assesses, mitigates and manages risks, which is vital to our business strategy and includes tax risks. All business strategies, including tax, are led and overseen by the senior management of Evercore, and ultimately overseen in the UK by the boards of the Evercore UK entities.
Our internal finance and tax teams, which regularly report to senior management, have established processes compliant with Sarbanes-Oxley Act (SOX), FCA, and HMRC tax requirements. The head of tax in the UK is responsible for the day-to-day management of UK tax compliance, planning and reporting.
We engage external advisers to provide additional assistance with tax compliance, including for supervisory review of Evercore UK’s business risk strategies, as well as to review our internal processes and procedures. External tax advice is also sought where the tax treatment of transactions is complex, unclear or uncertain under UK tax law.
Evercore does not tolerate tax evasion or the facilitation of tax evasion. Following the introduction of the new Corporate Criminal Offence of Failure to Prevent the Facilitation of Tax Evasion legislation, which came into force 30 September 2017 as part of the Criminal Finances Act 2017, Evercore UK seeks to apply appropriate procedures and controls to prevent any person acting on its behalf from facilitating tax evasion.
Tax consequences of transactions are taken into account as part of Evercore’s overall business decision making process, but transactions are driven by commercial rather than tax mitigation motives. Evercore does not implement or utilise any aggressive or marketed tax avoidance strategies or artificial structures. Evercore may take advantage of available tax reliefs or well established and accepted arrangements where this is provided for by law. All transactions have an underlying commercial substance and any related tax planning arrangements are in line with our tax strategy and low tax risk appetite. In accordance with OECD guidelines, all the intercompany transactions with Evercore UK entities are conducted on arm’s length principles.
Evercore has a low appetite for tax and regulatory compliance risk. Our low risk appetite is set by the senior management of Evercore and is influenced by our reputation as a leading independent investment banking advisory firm, in which context tax or regulatory failings could have a material adverse effect on our reputation and relationship with HMRC and key stakeholders (including shareholders, employees and clients) and our business. We aim to lower the risk and uncertainty by seeking appropriate external advice and engaging directly with regulatory bodies worldwide, including HMRC.
Our governance framework generally operates to ensure compliance with UK tax laws and regulations. This also ensures that we identify, assess and mitigate UK tax risks effectively.
Working with HMRC
We are committed to being compliant with all UK statutory obligations, filing requirements and/or tax disclosures with UK HMRC. Our relationship with HMRC is guided by our core values and high standards of business conduct. We work collaboratively wherever possible with HMRC to resolve disputes and obtain certainty in relation to UK tax risk, the UK tax treatment of proposed business transactions and the interpretation of UK tax law.
Entities covered by this tax strategy
This tax strategy applies to Evercore ISI International Limited, and the UK subgroup comprising: Evercore Holdings Limited, Evercore Partners Limited and Evercore Group Services Limited.
Date of Publication: January 16, 2019