UK Tax Strategy
SMFL LCI Helicopters Limited
SMFL LCI Helicopters Limited is an Irish subsidiary of SMFL Japan and is part of the wider SMFL group of companies. SMFL LCI Helicopters Limited holds Irish and UK subsidiaries (“SMFL LCIH Group” or “Group”). A list of the UK subsidiaries covered by this tax strategy can be found at Appendix 1.The Group is engaged in the leasing of aircraft, specifically helicopters. The Group’s strategy focuses heavily on minimising environmental impact whilst carrying out its operations.
The SMFL LCIH Group fleet includes a significant portion of aircraft placed in emergency medical services (EMS), search and rescue (SAR) and offshore windfarm transportation missions. With regards to these asset acquisitions, the growth of the fleet will be distinguished by the continued diversification of the types of helicopters being bought, the industry of its end-users, the geography of these end users and the lessees and lease terminations. The Group’s business features environmental, social, and governance friendly, long-term leases on full power by the hour maintenance contracts and comprises of customers across four continents in a number of different industries, with a focus on emergency medical services, offshore wind, search and rescue, maritime pilot transfer and offshore crew transportation.
The Group publishes this Tax Strategy in compliance with Section 19(2) and Schedule 19 of the UK Finance Act 2016.
UK Tax Governance and Risk Management
The Group’s policies and controls for UK tax governance and risk management are aligned with those of the wider international SMFL Group. The Group does not have any employees of its own, but is supported by tax services and third party professional tax service providers.
The Group is committed to understanding UK tax laws and regulations, as well as tax guidelines published by international institutions. The Group is also committed to understanding the tax laws and regulations of any jurisdiction relevant to its business and operations. The Group also monitors ongoing tax law changes which may affect the Group, ensuring that it is aware of possible tax risks and all compliance obligations.The Group ensures that their knowledge and understanding of UK tax requirements, such as UK tax strategy and tax compliance, is kept up to date. The Group strives to continually enhance their knowledge of tax and tax requirements.
The Group engages reputable external advisors to assist with UK tax compliance obligations as and when required. These obligations include filing tax returns, and reporting appropriately, and the Group endeavours to ensure that all obligations are met in a timely and accurate manner.
The Group also engages external advisors to provide tax advice on complex tax technical matters, ensuring that they understand the associated tax implications and obligations arising in the UK and any other relevant jurisdictions.
Tax Planning and Tax Compliance
The Group will only engage in tax planning that supports genuine commercial activity and will not engage in any inappropriate tax planning that merely seeks to derive a tax advantage or that is not consistent with legislative intent. does not engage in inappropriate tax planning or avoidance, which the Group believes is contrary to the intentions, purpose and spirit of the legislation. This is in line with the wider international SMFL Group tax policy.
The Group is committed to ensuring compliance with international tax rules. This includes transfer pricing rules and conforming to tax standards and guidelines published by international institutions (for example, the OECD).
The Group does not undertake any business activities or corporate reorganisations which are contrary to the intention, or the spirit, of the tax laws of the jurisdictions involved. The Group also does not undertake any activities that unduly mitigate tax burden, in the UK or other relevant jurisdictions. The Group applies these principles to guide tax planning decisions, ensuring that they maintain the highest level of compliance with local and international tax rules.
Tax Risk
The Group does not engage in inappropriate tax planning or avoidance and will not enter into arrangements in which a material tax risk is present. The Group consults with reputable external advisors to understand any UK tax risks and consequently acts in an appropriate manner to address any such possible risks.The Group endeavours not to provide or promote products which could cause controversy or suspicion for tax purposes when providing customers with its services. Alongside this, the Group strives not to engage in, or support, any transactions or activities whereby its customers could unduly avoid tax burden or their obligations for filing tax returns. This approach is aligned with the wider international SMFL tax policy.
The Group monitors the tax risks facing the Group, both from a financial and reputational standpoint.
All UK subsidiaries are fully subject to UK corporation tax and operate under an established tax compliance framework. As a result, the Group does not believe that a material UK tax risk exists. This risk will continue to be monitored, with a particular focus on the scope of the UK branch’s business operations and activities.
Relationship with HMRC
The Group is committed to fulfilling its obligations for filing UK tax returns, making tax payments and reporting to HMRC, whilst ensuring compliance with UK tax laws, regulations and double tax treaties.
Where required the Group will seek to engage to engage with HMRC proactively on any relevant areas, including seeking formal advance clearances on significant and material tax issues. The Group aims to develop a cooperative and transparent relationship with HMRC. When deemed appropriate, the Group will employ the services of external tax advisors to act as our agents, and in some cases, they may liaise with HMRC on our behalf.
Appendix 1: Entities covered by the Tax Strategy
The following UK entities are covered by this tax strategy:
- LCI Helicopters (UK) Limited
- Lease Corporation UK Limited
- LCIH Hobart Four Limited
- LCIH Hobart Three Limited
- SMFL LCI Helicopters UK Limited
- LCIH Australia Two Ltd
- LCIH Hobart Five Limited
- SMFL LCI Finance UK One Limited
- SMFL LCI Helicopters UK Two Limited
- LCI Analytics Limited