Graff Diamonds International Limited

Tax Strategy

December 2017


This strategy applies to all taxes relevant to the UK business and takes effect from the date of publication until superseded or otherwise replaced. This strategy is published in accordance with paragraph 19(2) of Schedule 19 of the Finance Act 2016.



Graff aims to demonstrate responsible tax management.  This includes defining the group’s approach to management of tax risk, appetite over tax planning and the importance of building and maintaining relationships with tax authorities that are open, constructive and based on mutual trust.

In line with Graff’s overall high standards of governance, the group’s tax affairs are managed in a way which takes into account the group’s wider corporate reputation.


Governance and compliance

Graff is committed to observing all applicable laws, rules and regulations in meeting the group’s tax compliance and reporting responsibilities in all jurisdictions where the business operates and ensuring that appropriate management structures are in place to meet those obligations.

In completing the group’s tax compliance requirements, Graff is committed to applying diligent professional care and judgement, ensuring all decisions are taken at an appropriate level and that all staff are appropriately qualified and experienced.

The group’s tax strategy is reviewed by the CFO and the Board on at least an annual basis.

The Board delegates responsibility for tax management to the Group CFO who in turn delegates day to day responsibility to the Group Tax Director who provides oversight and support to the management of tax across the organisation.

Some day to day decisions relating to routine tax matters including but not limited to Payroll, VAT and Customs Duty may be taken by other functions within the group and the Group Tax Director works with the wider group to set tax strategy.


Risk Management

Graff recognises that its business has undergone significant expansion overseas in recent years and faces an increasingly complex global tax environment.

Like most multinational organisations Graff faces tax risks due to the complexity of tax law and regulations as well as reputational risk, transactional risk and compliance and reporting risk.

Graff seeks to comply with its tax filing, tax reporting and tax payment obligations globally and has developed internal controls and processes to ensure these are met accurately and on a timely basis.

Graff has developed a methodology to identify, assess, prioritise and manage tax risk on a global basis using a tax risk register to enable the group to implement sufficient controls and mitigate identified risks.

Where risks are identified the Group Tax Director works with the business to develop a remediation plan and where appropriate engages with tax authorities to disclose and resolve issues, risks and uncertain tax positions.

Graff’s transfer pricing policy is aligned to the OECD guidelines and inter-company transactions are benchmarked using comparability studies and taking into account the functions, assets and risks of the various group entities to ensure appropriate profits are recognised in each jurisdiction.

Graff uses external advisers to provide tax technical advice, legal expertise and additional resource based on an assessment of risks and requirements.


Attitude to tax planning and level of risk

The group takes a conservative approach towards tax risk. It seeks to be efficient with its tax affairs and, in this context, will respond to tax exemptions and incentives only where they are compliant with Law and the intentions of Parliament and support sound commercial business activity that is aligned to the business strategy.

When providing significant transaction support or undertaking significant business decisions, Graff evaluates these within key tax risk parameters and will only accept those that pose a low tax risk. When deciding what is acceptable, consideration is given to the group’s reputation, brand, corporate and social responsibilities.

All transactions must be driven by business needs or commercial rationale and no transaction can be artificial in nature aimed solely at seeking a tax advantage.


Relationship with HMRC

Graff is committed to being open and honest with HMRC about the group’s tax affairs and to disclose relevant information to enable tax authorities to carry out their review.

Graff ensures that HMRC is kept aware of significant transactions and changes in the business and seeks to discuss any tax issues arising at an early stage.

When submitting tax computations and returns to HMRC, Graff discloses all relevant facts and identifies any transactions or issues where it considers that there is potential for the tax treatment to be uncertain.

Any inadvertent errors in submissions made to HMRC are fully disclosed as soon as reasonably practicable after they are identified.

Graff ensures that it meets the necessary standards of compliance for Authorised Economic Operators (AEOs).

Graff works with HMRC on a real time basis and has regular dialogue throughout the year as well as an annual meeting with the group’s Customer Relationship Manager.

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