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Rothesay is the largest UK specialist pensions insurer. We manage over £70.7bn of assets and pay the pensions of over one million people.

We are a responsible taxpayer and make a significant contribution to the UK’s economy through the investments we make, the services we provide and the tax we pay.  We conduct our business dealings in accordance with all tax laws, disclosure obligations and prevailing practice in the markets in which we operate.

This document is intended to meet the requirement to publish the Group tax strategy as set out under paragraph 16(2) of Schedule 19 of the Finance Act 2016.

Tax strategy

The Group’s strategy in relation to taxation is to ensure full compliance with the tax laws of those countries in which the Group operates and our intention is to pay the right amount of tax at the right time in each of the countries in which we operate. 

Governance and implementation

The Group’s tax strategy and tax policy are governed by the Board. The implementation of the strategy is supported  by appropriate internal policies, procedures, and systems, and is actively communicated to all employees. 

The Group’s Chief Financial Officer is responsible for ensuring that tax governance is consistently implemented across the organisation and that tax processes are appropriately followed, documented and controlled.

Day to day responsibility for tax compliance, risk management and general tax matters falls to the Co-Head of Finance and the Head of Tax, supported by external advisors as required. Employment tax matters are managed collaboratively between the finance function and the HR team. Policyholder taxes are the responsibility of the Operations team.

Approach to risk management

In addition to ensuring tax compliance, a key priority of the finance function is to manage tax risk on both a legal entity and transactional level. This is done in a cost-effective manner that aligns with the Group’s business model and overall strategy and is in line with the Board’s risk limits.  For more complicated matters, the Group seeks input from external advisors to assist with interpretation and application of tax legislation.

Tax processes are subject to oversight by the Group’s risk and compliance functions and by internal audit.

Attitude to tax planning

The Group adopts a low risk approach to tax planning. While the Group will aim to utilise available and legitimate tax incentives and reliefs,  any tax planning undertaken will have commercial and economic substance and will have regard to the Group’s corporate responsibilities, brand  and the potential impact on shareholders, policyholders and other stakeholders. The Group does not engage in contrived or artificial tax arrangements and has zero tolerance for tax evasion of any kind.

Relationship with tax authorities

The Group is committed to transparency in all of its tax disclosures, and is committed to maintaining an open, fair and proactive relationship with tax authorities at all times. Where appropriate, the Group engages with relevant tax authorities to discuss areas of uncertainty or to seek clarification on the interpretation of legislation. 

Approved by the Board in June 2025