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This strategy applies to Simple Energy Limited and to the group of companies headed by Simple Energy Limited in accordance with Schedule 19 of Finance Act 2016. A list of the entities to which it applies is set out below. In this strategy, references to ‘Bulb’, ‘the firm’ or ‘the group’ are to all these entities. This tax strategy was published on 20 March 2020 and Bulb regards this publication as complying with its duty under paragraph 16(2) Schedule 19 FA 2016 in its financial year ended 31 March 2019.

This strategy applies from the date of publication until it is superseded. References to ‘UK Taxation’ are to the taxes and duties set out in paragraph 15(1) of the Schedule which include Income Tax, Corporation Tax, PAYE, NIC, VAT, Insurance Premium Tax, and Stamp Duty Land Tax. References to ‘tax’, ‘taxes’ or ‘taxation’ are to UK taxation and to all corresponding worldwide taxes and similar duties in respect of which the Group has legal responsibilities.


Bulb is committed to full compliance with all statutory obligations and full disclosure to relevant tax authorities. The group’s tax affairs are managed in a way which takes into account the group’s wider corporate reputation in line with Bulb’s overall high standards of governance.

Governance in relation to UK taxation

Ultimate responsibility for Bulb tax strategy and compliance rests with the Board of Bulb. Executive management of the group is delegated by the Board to the Chief Executive Officer (‘CEO’) and the Senior Leadership Team (‘SLT’).

The Chief Financial Officer (‘CFO’), reports to the CEO and holds executive responsibility for tax matters.

Day-to-day management of Bulb’s tax affairs is delegated to the Group Financial Controller, who reports to the CFO, with assistance from external advisers. The Board’s requirement to monitor the integrity of Bulb’s financial reporting system, internal controls and risk management framework, expressly includes those elements relating to taxation.

The Board ensures that Bulb’s tax strategy is one of the factors considered in all investments and significant business decisions taken. The CFO reports to the Board on Bulb’s tax affairs and risks during the year.

Risk Management

Bulb operates a system of tax risk assessment and controls as a component of the overall internal control framework applicable to the group’s financial reporting system.

Bulb seeks to reduce the level of tax risk arising from its operations as far as is reasonably practicable by ensuring that reasonable care is applied in relation to all processes which could materially affect its compliance with its tax obligations.

Processes relating to different taxes are allocated to appropriate process owners, who carry out a review of activities and processes to identify key risks and mitigating controls in place. These key risks are monitored for business and legislative changes which may impact them and changes to processes or controls are made when required.

Appropriate training is carried out for staff outside of the core Finance team who manage or process matters which have tax implications.

Advice is sought from external advisers where appropriate.

Attitude towards tax planning and level of risk

Bulb manages risks to ensure compliance with legal requirements in a manner which ensures payment of the right amount of tax.

When entering into commercial transactions, Bulb seeks to take advantage of available tax incentives, reliefs and exemptions in line with, and in the spirit of, tax legislation. Bulb does not undertake tax planning unrelated to such commercial transactions.

The level of risk which Bulb accepts in relation to UK taxation is consistent with its overall objective of achieving certainty in the group’s tax affairs. At all times, Bulb seeks to comply fully with its regulatory and other obligations and to act in a way which upholds its reputation as a responsible corporate citizen. In relation to any specific issue or transaction, the Board is ultimately responsible for identifying the risks, including tax risks, which need to be addressed and for determining what actions should be taken to manage those risks, having regard to the materiality of the amounts and obligations in question.

Relationship with HMRC

Bulb seeks to have a transparent and constructive relationship with HMRC where appropriate in respect of developments in Bulb’s business, current, future and retrospective tax risks, and interpretation of the law in relation to all relevant taxes.

Bulb 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, Bulb discloses all relevant facts and identifies any transactions or issues where it considers that there is potential for the tax treatment to be uncertain.

Bulb seeks to ensure that any inadvertent errors in submissions made to HMRC are fully disclosed as soon as reasonably practicable after they are identified.

List of entities covered by this Tax Strategy

Simple Energy Limited and its non-UK subsidiaries

Bulb Energy Limited