InterGen UK Group Tax Strategy

Year ended 31 December 2023

InterGen is a UK based, independent generator that has developed and operated flexible gas assets for the last 25 years.  InterGen’s three gas fired plants generate enough power to supply three million homes, representing around 5% of the UK’s electricity demand.  InterGen is a world class developer of energy assets with a 3GW pipeline of battery projects at the heart of the company’s plan to help decarbonise the GB energy mix and enhance system operability.

The entities undertaking InterGen’s operational and development activities, along with certain associated service entities (referred to collectively as “InterGen UK”), are subject to UK taxes.

Approach to risk management and governance arrangements in relation to UK tax

InterGen UK has been assessed as a Low Risk taxpayer by HM Revenue and Customs (“HMRC”), the UK Tax Authority.   InterGen UK values this status and is committed to maintaining the governance and the behaviours that have underpinned this assessment to date.

  • InterGen UK is subject to a Delegation of Authority (“DOA”) which has been approved by the Board of Directors (“the Board”) of the holding company of the InterGen UK group.  The DOA is central to the governance and decision making structure in the organisation. The DOA determines firstly, where the Board has determined that a decision can be delegated and secondly, the approvals required at each level of delegation.  This process aims to ensure that decisions are made taking account of the risks and mitigants identified by suitably qualified and skilled people at an appropriate level in the organisation.
  • The respective Boards of Directors of InterGen UK are ultimately responsible for ensuring that the affairs of these entities are delivered in accordance with this Tax Strategy.  Under the DOA, the Tax Director has day to day responsibility for identifying and managing tax risks and approving decisions, in accordance with this Strategy, from a UK tax perspective.  Decisions of the entities which relate to matters over defined materiality thresholds also require the Board approval.
  • InterGen considers that it has a robust internal controls framework which applies to its financial reporting system.  This includes the people, processes and systems required to deliver our Tax Strategy.  InterGen’s Chief Financial Officer requires that InterGen UK monitors, maintains and seeks to continuously improve this to ensure compliance, as required, with Senior Accounting Officer legislation.
  • Tax risks which are identified in relation to InterGen UK are communicated to UK directors; material risks are communicated to the Audit Committee, the Board and Shareholders on a timely basis.  The Audit Committee aims to ensure that appropriate governance structures are in place to support an effective control environment.
  • InterGen UK’s Tax Team is an integral part of the Finance function.  While the Tax Team members hold recognised professional qualifications and undertake technical training and other relevant Continuing Professional Development activities,  a key part of its risk management activities include identifying specialist technical matters and material uncertainties which may require further consideration to support a tax position or understand a potential risk.  The Tax Team will engage specialist external advice, as required, taking account of a number of factors including the amount of tax potentially at stake and the complexity of the issue.

Attitude of the UK group towards tax planning

Integrity is one of InterGen’s core values.  InterGen UK is therefore committed to ensuring it is compliant with all applicable tax laws, rules, regulations and reporting requirements that relate to UK tax.  We will look to ensure we claim all applicable tax reliefs and benefits where it is beneficial to do so on a timely basis.

InterGen UK will aim to structure its commercial activities to ensure they are optimum from a legal, financial, tax and treasury perspective.  While tax is one of a number of factors that is considered when undertaking business transactions, we do not undertake transactions primarily for tax planning purposes.

Level of risk the UK group is prepared to accept in relation to UK tax   

InterGen UK considers it has a low tolerance towards tax risk and we value the opportunity to have certainty or early resolution of potential tax issues throughout the lifecycle of our assets.  InterGen UK evaluates the existence of risk taking into account factors such as previous experience of the issue, the existence of relevant guidance and precedent and external advisor opinions.  Where there is a significant uncertainty, we have sought formal Clearance/Ruling requests where relevant.

Approach of the group towards dealing with HMRC

Consistent with its aim for certainty or early resolution of potential tax issues, InterGen UK is committed to maintaining an open, transparent relationship with HMRC, through proactive and appropriate interactions with our Customer Compliance Manager (“CCM”) and technical specialists.

We aim to ensure that our tax obligations are delivered on a timely and accurate basis.  However, in the event that we discover an error in a submitted return, we will seek to disclose this to HMRC on a voluntary basis.  Through this disclosure, we will aim to quantify and settle any additional liabilities due.  In addition, we will identify what we believe to be the cause of the error and outline any remedial actions we propose to prevent recurrence.

Approved on 21 December 2023 by the Board of Directors of InterGen Projects (UK) Limited, on behalf of it and its UK tax resident subsidiaries, in accordance with paragraph 16 (2) Schedule 19 Finance Act 2016