The process

I had to understand tax. A lot. I don’t understand tax, because it’s often written about using lengthy, complicated syntax and unhelpful jargon, but getting to the bottom of new and complicated topics is what I love doing, so this was a blast.

I then had to render what I’d learned in readable, easy-to-understand English, and then do another draft to make sure I kept Bulb’s tone of voice.

After I’d done that, I worked with Bulb’s lawyers and CFO to make sure I hadn’t sacrificed meaning or accuracy for style and tone. For documentation like this, finding a balance is key.

The outcome

After being ratified by both Bulb’s CMO and CFO, my non-taxing copy in Bulb’s voice was published at bulb.co.uk/tax-strategy in June 2020.

Bulb is now no more, so my copy is below.

How we manage our taxes

The UK government wants all large companies operating in the UK to publish how they manage their taxes, and that includes Bulb. It's important to us that we explain things clearly, even something as complicated as tax. So here goes.

About this statement

We've put together the following information in accordance with the Finance Act 2016. Specifically, paragraph 16(2) of Schedule 19. 

We first published it on 20 March 2020, in relation to our financial year ending 31 March 2020. Then we rewrote it using simpler words on 8 June 2020. Everything we've written below applies from then on, until we replace it.

By 'taxes' we mean all UK taxes and duties set out in paragraph 15(1) of Schedule 19 of the Finance Act 2016, including income tax, corporation tax, PAYE, NIC, VAT, insurance premium tax, and stamp duty land tax. We may refer to 'tax', 'taxes' or 'taxation', but we mean the same thing.

Who we are

First off, let's be clear who we're talking about. We means us. Bulb. Your friendly energy company. Or, more specifically, Bulb Energy Ltd, which is our official company name. 

The following information also covers our parent company Simple Energy Ltd and all its non-UK subsidiaries. So when we use 'Bulb' or 'we', we mean the group of companies headed by Simple Energy Ltd and including Bulb Energy Ltd. 

And if we refer to 'the group' or 'the firm', then we mean this same group too.

Our board makes sure we pay our UK and international taxes correctly

Bulb's board of directors is ultimately responsible for making sure we comply with UK and international laws when it comes to taxes. 

The board delegates executive management of the group to Bulb's Chief Executive Officer (CEO) and Senior Leadership Team (SLT).

The Chief Financial Officer (CFO) is in charge of paying our taxes and reports to the CEO. The CFO delegates day-to-day management of our taxes to Bulb's Group Financial Controller, who works with external advisers and reports to the CFO. It's then the CFO's job to report back to the board about our tax affairs and risks throughout the year. 

The board also expects the SLT to monitor the integrity of Bulb's financial reporting system, internal controls and risk management framework. This requirement specifically includes taxation. And the board makes sure all our investments and significant business decisions take into account how we manage our taxes too.

How we manage tax risk

'Tax risk' means the possibility that some of the information we report, given the size and complexity of our business and number of tax obligations, is inaccurate or incomplete, leading to us paying too little or too much tax. We'd be penalised by the tax authorities if that happened and would damage our reputation.

So we lower the risk of that happening as much as we reasonably can and take care to make sure we comply with all our tax obligations. We do that through a system of assessment and controls. These form part of a wider framework of processes that check whether our financial reporting is working as it should.

We allocate each process relating to tax to an appropriate process owner. They review it to identify the important risks and work out what we can do to mitigate them. We then monitor the business and legislative changes that may trigger these risks, and make changes to our processes and controls if we need to.

We also train any staff outside of the core finance team who manage or process anything that has tax implications.

And where appropriate, we seek advice from external advisers.

How we plan tax and control level of risk

We try to make use of any available tax incentives, reliefs and exemptions whenever we make business deals or carry out any kind of commercial transaction. But only so long as they're in line with – and in the spirit of – tax legislation. We don't carry out tax planning beyond that.

As a business, we can only budget and plan our next steps if we know how much tax we're likely to pay. This is known as 'tax certainty', and we try to achieve it in all our tax affairs. That includes managing the level of risk we're willing to accept. 

The Board is ultimately responsible for identifying any risks, including tax risks, that arise from a specific issue or transaction. It's also responsible for deciding how we manage those risks, taking into account how big they are and the obligations that need to be met. Whatever we do, we make sure we comply with all legal requirements and pay the right amount of tax. 

Being a good corporate citizen is important to us. We're also proud of our status as a certified B-Corp, and aim to uphold it by complying fully with all regulatory and other requirements. 

Our relationship with HMRC

We're transparent and helpful in all our dealings with HMRC. We'll contact them when there are changes to our business, when we need to assess current, future and retrospective tax risks, and when we need to clarify the law in relation to certain taxes.

We make HMRC aware of any significant transactions and changes to our business, and discuss any tax issues with them at an early stage. And when we submit our tax calculations and returns, we give HMRC all relevant information and highlight any transactions or issues where there’s a possibility that the way they’re treated for tax purposes might change.

As much as we aim to make accurate submissions to HMRC, some mistakes are inevitable. We'll let HMRC know as soon as we find out we've made one.

In the UK, our largest market, we adhere to the Senior Accounting Officer legislation, which requires our Chief Executive Officer to confirm to HM Revenue & Customs on an annual basis whether our tax processes are appropriate.

And there we have it. We hope this makes our taxes simpler to understand.

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