This document, approved by the board of Trenitalia UK (the Company), sets out the approach of the Company and its wholly owned subsidiary, Trenitalia c2c Limited (together, the Group) to conducting tax affairs and dealing with tax risks. The current tax years for Trenitalia UK and Trenitalia c2c end on 31 December 2023 and 31 March 2024 respectively.

The Group is committed to:

  • Following all applicable laws and regulations relating to its tax activities;
  • Maintaining an open and honest relationship with the tax authorities based on collaboration and integrity;
  • Applying diligence and care in our management of the processes and procedures by which all tax related activities are undertaken and ensuring that our tax governance is appropriate;
  • Using incentives and reliefs to minimise the tax cost of conducting our business while ensuring that these reliefs are not used for purposes which are knowingly contradictory to the intent of the legislation.

Risk management

The Group has clearly defined lines of responsibility for its tax affairs, with decisions being taken in line with the Group’s tax authority thresholds.

Eliminating tax risks entirely is impossible, therefore the Group’s attitude towards the level of control required over the processes designed to reduce these tax risks is driven by the likelihood of occurrence and scale of impact of each risk.

The identified tax risks are then assessed on a case-by-case basis, allowing the Group to arrive at well-reasoned conclusions on how each individual risk should be managed.  Where there is uncertainty in how the relevant tax law should be applied, external advice is sought to support the Group’s decision-making process.

When reviewing the tax risks associated with a specific decision or action, the Group ensures that the following are considered:

  • The legal and fiduciary duties of directors and employees;
  • The requirements of any related internal policies or procedures;
  • The maintenance of the Group’s corporate reputation, having regard to the way we interact with the communities around us.

Tax planning

The Group’s tax planning aims to support the commercial needs of the business by ensuring that the companies’ affairs are carried out in the most tax-efficient manner whilst remaining compliant with all relevant laws. The tax function is therefore involved in commercial decision-making processes and provides appropriate input into business proposals to ensure a clear understanding of the tax consequences of any decisions made.

In cases where the tax guidance is unclear or the Group does not feel it has the necessary expert knowledge to assess the tax consequences adequately, external advice is sought to support the Group’s decision making process.

Approach towards dealings with HMRC

The Group is committed to the principles of openness and transparency in its approach to dealing with HMRC, and in particular the Group commits to:

  • Make fair, accurate and timely disclosure in correspondence and returns, and respond to queries and information requests in a timely fashion;
  • Seek to resolve issues with HMRC in a timely manner, and where disagreements arise work with HMRC to resolve issues;
  • Be open and transparent about decision-making, governance and tax planning;
  • Ensure all interactions with HMRC are conducted in an open, collaborative and professional manner.