As a Canadian tax-exempt Crown corporation and investment manager for the pension plans of the federal public service, the Canadian Forces, the Royal Canadian Mounted Police and the Reserve Force, Public Sector Pension Investment Board (“PSP Investments”) operates with an appropriate degree of transparency. Consistent with this, we believe that it is appropriate to publish a statement setting out our approach to tax matters in those jurisdictions in which we operate and hold investments.
The key principles guiding our global approach to tax are as follows:
- We aim to pay the amount of tax legally due, consistent with the letter and intent of the law in question, and to comply with all associated tax filing obligations in a timely and accurate manner.
- We do not take speculative or unsustainable positions on points of technical uncertainty.
- We give due consideration to tax structuring opportunities, but only where they are consistent with the above criteria.
- We reflect in our financial statements the expected outcomes of any tax positions taken.
- We do not seek to take undue advantage of available tax concessions and/or exemptions, nor do we allow third parties to benefit from our tax-exempt status.
- We promote tax awareness both within PSP Investments and with our business partners through knowledge sharing and best practices.
- We aim to uphold these principles in our wholly-owned entities and in our investments in which we have majority ownership positions.
We have clearly defined roles and responsibilities within PSP Investments to oversee and monitor the implementation of the above principles. Ultimate ownership of our tax strategy (along with our overall business strategy) sits with our senior leadership team and PSP Investments’ Board of Directors. PSP Investments’ Chief Financial Officer (“CFO”) and other senior leaders are regularly briefed on relevant tax issues and tax policy developments of interest. Day to day responsibility for developing, reporting on, and overseeing adherence to PSP Investments’ tax strategy and group tax compliance rests with our Taxation Department, led by the Head of Taxation (who in turn reports to the CFO).
Within the Taxation Department, we maintain a high level of internal tax expertise through continuous development, selective hiring, and (where appropriate) utilization of external advisors. Our Taxation Department assesses all proposed non-publicly traded investments and transactions to which we are party in light of the above principles, ensuring proper alignment while managing and monitoring our tax risks. In assessing a proposal, we take into account the following different types of tax risk:
- Technical risk (arising from the possibility that a tax authority will adopt a different interpretation of relevant tax law);
- Operational risk (arising from inadequate processes, or a failure to follow adequate processes);
- Reputational risk (arising when a proposed tax position is inconsistent with widely understood tax policy objectives);
- Legislative risk (arising due to changes in tax laws or administrative practices); and
- Systemic risk (arising from a high concentration of similar tax positions across our investment portfolio).
We maintain internal guidelines in relation to each of these risks which operationalize the general principles described above and provide further practical steps to be taken to mitigate the relevant risk.
We also believe it is important to maintain an appropriate level of transparency and cooperation with relevant stakeholders and government bodies, including tax authorities, and to develop and foster constructive relationships with them. We assume that any tax position taken by us may be examined by a competent taxing authority having full knowledge of all the relevant information, and we therefore seek to take only positions which we would be comfortable to have fully scrutinized and where we believe PSP Investments’ position would prevail. Where differences of opinion do arise, or if compliance issues are identified, we will be proactive in our engagement with the relevant tax authority. We will also engage, when suitable, with policy makers to participate in the development and execution of tax policy.
This tax strategy statement is published on behalf of PSP Investments and its wholly-owned entities (collectively ‘we’ or ‘our’). Publication of this strategy is regarded as complying with Part 2 of Schedule 19, Finance Act 2016 in the United Kingdom for the year ended 31 March 2019.