Automatic Data Processing Inc (“ADP” or “the Group”) – Tax Strategy for the year ended 30 June 2019
This tax strategy applies to ADP’s UK sub-group and UK companies in compliance with the corresponding paragraphs (as detailed below) under Schedule 19, Finance Act 2016:
UK sub-group under Para 19(2):
- ADP Network Services Limited (head of UK sub-group)
UK companies under Para 22(2):
- Business Management Software Limited
- ADP RPO UK Limited
Overview of Group’s operations
ADP is a provider of human resources management software and services, employing 57,000 people worldwide. We provide cloud-based human capital management solutions that integrate HR, payroll, talent, time, tax and benefits administration as well as being a leader in business outsourcing services, analytics and compliance. Further information about us can be found on our website www.adp.com.
Our tax strategy is built on the foundation of one of our core values, ‘Integrity is everything’ where we conduct our business with the highest level of integrity. Accordingly, we are a responsible tax payer and comply with all applicable tax laws.
a. The approach of the Group to risk management and governance arrangements in relation to UK taxation
The ultimate responsibility for the Group’s tax strategy lies with the Board of Directors.
Directors of each legal entity have a duty to ensure that risk is managed and that appropriate procedures and controls are in place. Directors are also responsible for the day-to-day management of local tax obligations.
The Group and its entities are supported by a global team of in-house tax experts led by the Staff Vice President of Corporate Tax, who reports in to the Corporate Vice President & Chief Financial Officer. ADP is also supported by external tax advisors in respect of local tax expertise.
With respect to the UK companies and UK taxes, ADP is committed to meeting its legal and regulatory requirements, including filing applicable tax returns and making required tax payments when legally due. The directors who have oversight of the UK companies are based in the UK, Singapore and the US. They communicate as and when needed, for example, if any significant tax related matters arise.
The UK tax team is supported by in-house tax experts based in Paris and the US who cover the EMEA region. The support provided includes transfer pricing, major projects which may have tax implications, record maintenance and completion of tax returns. All returns and other submissions are checked by the Head of Accounting (or another appropriate individual) before filing.
ADP’s internal audit function completes regular independent reviews of our processes and controls. With respect to the UK companies, the internal audit is carried out by the internal audit function (and sometimes external auditors, if required) who are based in Paris and the US. The internal audit takes place every year with a scope of work being agreed at the beginning of the year in relation to key audit risks.
Their assessments and observations are reported to the Audit Committee, either in an Audit Committee meeting (for key observations) which includes the Corporate Vice President & Chief Financial Officer or via a memorandum (for general/low risk observations).
b. The attitude of the Group towards tax planning (so far as affecting UK taxation)
The Group adopts a prudent approach to tax planning while at the same time, supporting the strategy and operations of the business.
In doing so, we are committed to fulfilling our legal obligations therefore adhering to tax laws in the territories in which we operate.
In the event of complexity and uncertainty we seek advice from our external tax advisors to ensure we remain compliant.
c. The level of risk in relation to UK taxation that the Group is prepared to accept
We consider that we have a low tolerance for tax risk and we seek to minimise the risk of uncertainty and tax disputes.
We aim to minimise risk and actively seek to comply with all applicable laws and regulations. Our management and approach is designed to help maintain a low level of risk and support our core values. The Group’s tax department actively and continuously identifies and monitors tax risks so they remain aligned to the operational and strategic objectives. If any risks are identified, the Group is supported by the in-house tax experts and/or external advisors to manage these appropriately.
d. The approach of the Group towards its dealings with HMRC
ADP adopts an open and transparent approach in working with HMRC. We work collaboratively and respond to information requests in a timely manner. We are committed to making accurate disclosures in all our tax-related filings, submissions and correspondence with HMRC. Where needed, we look to discuss and disclose any matters that arise directly with HMRC and seek resolution with HMRC in as efficient a manner as possible.
Approved on 14 May 2019 by the Boards of Directors of ADP Network Services Limited (on behalf of it and its UK subsidiaries) and ADP RPO UK Limited, in accordance with paragraphs 19(2) and 22(2) Schedule 19 Finance Act 2016 and approved on 20 May 2019 by Business Management Software Limited