UK tax strategy

In compliance with our duty under Section 16(2) Schedule 19 of the Finance Act 2016 we set out below our UK tax strategy for the financial year ended 31 December 2019.

Introduction

Markel Corporation is a US-based diverse financial holding company with operations around the world. Its operations in the UK are divided into 3 categories as follows:
  • Markel International Limited (MINT) - The principal business of the MINT group is the marketing and underwriting of specialty insurance products. For a list of UK companies within the MINT group please see below.
  • Nephila - The principal business of the Nephila group is investment management in a broad range of investment products, including insurance-linked securities, catastrophe bonds, insurance swaps, and weather derivatives. For a list of UK companies within the Nephila group please see below.
  • AMF Bakery Systems (UK) Ltd - This company sits within the Markel Ventures group. Markel Ventures owns and operates a family of companies outside the insurance industry. The principal business of the company is to sell bakery equipment, parts, and services.

The Markel Style is our corporation’s statement of commercial ethos and is found at markelcorp.com/about-markel/markel-style

Markel’s financial goals are to earn consistent underwriting and operating profits and superior investment returns to build shareholder value. The UK tax strategy of Markel is consistent with such objectives. Markel has a strong focus on corporate responsibility and a commitment to the communities in which it operates and we consider responsible administration and payment of taxes as an obligation of our doing business.

  • Pay the right amount of tax, in the right jurisdiction and at the right time, in accordance with applicable laws
  • Consider tax in major business decisions as well as in the context of our reputation and brand
  • Develop and comply with appropriate tax risk processes and ensure Board oversight with respect to such processes and compliance

Above all, the Markel UK tax strategy reflects the honesty and fairness that we commit to in the Markel Style.

We seek to deliver long-term economic growth value to our shareholders while complying fully with tax laws and regulations that apply in all the territories in which we operate. In our view our shareholders would expect no less.

While we undertake tax planning as part of our overall business strategy we do not enter into abusive tax planning transactions nor do we engage in transactions that have no commercial rationale in order to obtain a tax benefit. From time to time we do undertake transactions that have a clear commercial rationale and that also produce a beneficial tax outcome. In those circumstances we take into account both the letter of the law and the intent of the law seeking counsel from external experts where appropriate to ensure that our interpretation of the law is reasonable and consistent with market practices.

Our tax arrangements are based on commercial business and economic activities. We rarely undertake transactions or employ tax planning strategies that do not have a clear and certain tax outcome. When such circumstances do arise we seek professional opinions and tax advice from independent external advisors to provide comfort that the tax outcome is more likely than not to be correct. Where appropriate we seek to engage with tax authorities to disclose and resolve tax issues, risks, and uncertain tax positions.

As taxation is a key component of meeting our wider business objectives we believe that tax risk should be prudently managed. To that end we have established policies for the management and governance of tax risks and regularly review the processes and controls embedded in those policies. The governance of tax risk exposure is a matter for the Board of Directors of MINT, Nephila, and AMF Bakery Systems (UK) Ltd to consider, and updates on taxation matters are provided to each by their respective Finance Directors. All members of the Markel group are required to comply with the Markel risk management framework and tax risk is reviewed periodically by their risk management or compliance function and on an ad-hoc basis by Internal Audit. Additionally we engage regularly with our external auditors to whom we make a full and complete disclosure of all material taxation issues as part of their audit.

In keeping with the ethos of the Markel Style we seek to maintain open and honest relationships with HMRC and other taxation authorities in all the territories in which we operate, to treat them with the respect that we would in turn expect from them and to engage with them on a real-time basis on any matters of significance or concern. In the UK we regularly engage with HMRC through our Head of Tax to discuss our tax affairs, striving to address potential issues quickly and in a collaborative manner. In short, we endeavour to display respect, cooperation, and integrity in all our dealings with tax authorities.

MINT group UK companies

Markel Protection Ltd

Abbey Protection Ltd

Markel Consultancy Services Ltd

Accountax Law Ltd

ACCTX Consulting Ltd

ACCTX UK Ltd

Alterra at Lloyd’s Ltd

Alterra Capital America Ltd

Alterra Capital Brazil Ltd

Alterra Capital Service UK Ltd

Alterra Capital UK Ltd

Alterra Corporate Capital 2 Ltd

Alterra Corporate Capital 3 Ltd

Alterra Corporate Capital 4 Ltd

Alterra Corporate Capital 5 Ltd

Alterra Corporate Capital 6 Ltd

EC Insurance Co Ltd

Effective Tax Solutions Ltd

FSB Insurance Services Ltd

Galleon Marine Insurance Agency Ltd

Janjer Ltd

Markel (UK) Ltd

Markel Capital Holdings Ltd

Markel Capital Ltd

Markel Europe Ltd

Markel International Insurance Company Ltd

Markel International Services Ltd

Markel Syndicate Management Ltd

Markel Underwriting Services Ltd

Terra Nova Pension Trustee Ltd

Markel International Holdings Ltd

Nephila group UK companies

Volante Global Ltd

Volante Transaction Solutions Ltd

Volante Emerging Markets Ltd

Volante Global (Services) Ltd

Volante International Ltd

VTX Partners Ltd

Horizon Europe Management Ltd

Nephila Advisors (UK) Ltd

Nephila Syndicate Management Ltd

Nephila Syndicate Management Services Ltd

Nephila Syndicate Management Holdings Ltd