Our approach to tax

HCA Healthcare UK provides private healthcare predominantly across London, Birmingham and Manchester. From complex and urgent care, to primary care, outpatient and day-case treatment, we aim to provide exceptional care across our network of facilities and key NHS partnerships.  HCA Healthcare UK employs over 7,000 people in the UK.

This tax strategy applies to our UK sub-group headed by HCA UK Holdings Ltd (“HCA UK Holdings”) together with the following entities: Health Trust Europe Company Ltd and Cerecore International Holdings Ltd (all entities together are collectively referred to in this strategy as “HCA UK”) - and has been published in accordance with paragraphs 19(2) and 22(2) of Schedule 19 of the Finance Act 2016. This strategy applies from the date of publication until it is superseded. It reflects the policy and principles for the management of taxes and duties set out in paragraph 15(1) of Schedule 19 FA 2016 which includes Corporation Tax, PAYE, NIC, VAT, Insurance Premium Tax, Stamp Duty Land Tax, Stamp Duty Reserve Tax, Customs & Excise Duties and, Employee taxes and Withholding Taxes.

Our tax governance

The VP Corporate Finance & Controller has responsibility for tax and communicates with and advises the HCA UK Holdings’ Board of Directors (“Board”) on any significant tax matters, to ensure:

• The proper control and management of tax risk;
• The tax position is planned in line with the UK Group’s strategic objectives.

The HCA UK tax team will report material tax sensitive items to the VP Corporate Finance & Controller who will raise these issues with the HCA UK Chief Financial Officer where required. The HCA UK Chief Financial Officer and the VP Corporate Finance & Controller will determine whether to escalate any queries to the Board, Legal Department, HMRC or any other specialist advisor. 

How we arrange our tax affairs

HCA UK is committed to complying with all applicable UK tax laws and filing obligations. We maintain an open, honest and proactive relationship with HMRC.

A number of factors are considered during our tax planning process, including commercial purpose, legislation and HMRC guidance, our risk-averse stance and external advisors’ opinions.

How we manage our tax risks

Our approach to tax risk is based on principles of reasonable care and materiality. Tax risks are assessed on a case by case basis considering their impact and likelihood, and are escalated via the appropriate levels of management, ultimately to the Board.

Where appropriate e.g. uncertainty in interpreting the relevant tax law, external advice may be sought to support our decision-making process.

The HCA UK tax team works alongside the Finance and Legal functions to provide appropriate input into business proposals to ensure a clear understanding of the tax consequences of any decisions made.

We continually improve the efficiency of our business functions by ensuring that we have experienced personnel, adequate resources and expertise, and using market leading technology which supports our tax and financial reporting. We also have regular training in order to develop tax awareness across our business functions.

Effective risk management is paramount for HCA UK and underpins our business strategy. Our appetite for risk is a carefully calibrated part of the business model aligned to our strategic and corporate objectives, and considering the factors outlined above.

Our reputation and brand are very important to us, and we have a low tolerance for transactions which have the potential to damage these.  In determining our tax risk tolerance, we consider the interests of our key stakeholders, such as consumers, customers, and other third parties with whom we operate in partnership.

Our relationship with HMRC

We are committed to having an open, honest and proactive relationship with HMRC.

We maintain a regular dialogue with HMRC covering all areas of UK taxation. We seek to obtain advance clearances where tax treatments are uncertain and discuss contentious issues with HMRC in advance of filing where appropriate.

We ensure that our tax returns include full disclosure of significant transactions. We rigorously review our tax returns and other filings. In the event of errors being identified, we work collaboratively with HMRC in order to resolve these as soon as possible.

The publication of this tax strategy is in compliance with HCA UK’s duty under paragraphs 19(2) and 22(2), Schedule 19, Finance Act 2016 and relates to the year ending 31 December 2024. It has been approved by the Board of Directors of HCA UK Holdings Limited on 12 December 2023.