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Shanghai Pudong Development Bank Co., Ltd. London Branch Tax Strategy 2026

Background

Shanghai Pudong Development Bank Co., Ltd. London Branch (“the Branch”) forms part of Shanghai Pudong Development Bank Co., Ltd. (“SPD Bank”), a joint-stock commercial bank headquartered in Shanghai, China.

The Branch commenced operations in February 2018 to facilitate cross-border business between China and the United Kingdom and to support participation in the UK financial market.

This Tax Strategy sets out the Branch’s approach to managing its UK tax affairs.  It applies to all UK taxes relevant to the Branch’s activities and is published in accordance with Paragraph 22(2), Schedule 19 of the Finance Act 2016.  This strategy relates to the financial year ending 31 December 2025 and is reviewed periodically and updated as required.

Governance & Risk Management

The Branch is committed to maintaining robust tax governance and a strong control environment.  It recognises the importance of managing tax risk in a manner that safeguards its reputation and ensures full compliance with applicable laws and regulations.

The Branch operates within the wider governance framework of SPD Bank, with responsibility for UK tax matters, delegated to the London Branch by Head Office.

The Management Committee has ultimate responsibility for the Branch’s tax affairs, including its tax governance and controls, complying fully with its tax obligations. The Management Committee comprises the General Manager and two Deputy General Managers and the Chief Risk Officer. The Finance Department is overseen by the Deputy General Manager responsible for Finance and led by the Head of Finance. The department is responsible for implementing the tax procedures and policies.

Day-to-day responsibility for tax matters sits with the Finance Department, led by the Head of Finance and overseen by the Deputy General Manager responsible for Finance with support from other functions where appropriate.  

The Branch’s governance framework is further supported by key committees including the Management Committee, the Asset and Liabilities Committee and the Risk Management Committee.

The Branch provides regular reporting to Head Office in Shanghai on business operations, including tax compliance and administration.

The governance framework is supported by an independent internal audit function, which provides assurance that tax risks are appropriately identified, managed and controlled.

Material tax risks are escalated to senior management where appropriate and are managed in line with the Branch’s broader enterprise risk management framework.

New products, transactions and business initiatives are subject to internal governance, risk, and control processes, including consideration of tax implications.  The Finance function is consulted to ensure that tax compliance requirements are appropriately addressed.

Approach to Tax Planning and the Level of Tax Risk

The Branch adopts a prudent and responsible approach to tax planning and seeks to comply fully with all relevant tax legislation and reporting requirements.

The Branch maintains a low appetite for tax risk and manages such risk in line with its broader enterprise risk management framework.  Tax positions are assessed with regard to their technical merits, compliance with applicable law, and potential reputational impact.

The Branch seeks to ensure that tax liabilities are accurately determined and that the appropriate amount of tax is paid in the correct jurisdiction at the appropriate time, in accordance with applicable laws and regulations.

The Branch may utilise available tax reliefs and incentives where appropriate, in a manner consistent with both the letter and the spirit of the law.  

The Branch does not engage in artificial tax avoidance arrangements and will not undertake transactions that lack genuine commercial substance or are primarily designed to secure a tax advantage contrary to legislative intent.  

External advisors are engaged where appropriate, particularly in areas of complexity or uncertainty, to support compliance and ensure the accuracy of tax positions.

The Branch is committed to maintaining high standards of tax compliance and administration.  This includes the timely and accurate submission of all relevant tax returns, the maintenance of appropriate records and supporting documentation, and the prompt payment of all tax liabilities.  Appropriate systems, processes and controls are in place to ensure the integrity and accuracy of tax reporting.

Relationship with UK tax authorities

The Branch seeks to maintain a proactive, transparent and constructive working relationship with HM Revenue & Customs (“HMRC”)

Where there is uncertainty regarding the interpretation or application of tax law, the Branch will engage with HMRC directly or seek advice from external specialist tax advisors to ensure appropriate treatment.  

The Branch engages with HMRC on a timely basis and is committed to open communication, including making accurate and timely disclosures.  It cooperates fully with any HMRC enquiries, audits or compliance reviews and seeks to resolve matters in a collaborative and efficient manner.

Approval

The Tax Strategy has been approved by the Management Committee and is reviewed periodically to ensure it remains appropriate and aligned with the Branch’s business activities and regulatory obligations.