Scope
Following the acquisition of Charles Stanley Group (CSG) and its subsidiaries – principally Charles Stanley & Company Limited (CSC) – by Raymond James Financial, Inc. on 21 January 2022 both CSC and CSG are now part of the Raymond James group of companies.
This document sets out Raymond James approach and strategy for handling its tax affairs and managing the tax risks for the year ending 30 September 2022 for Raymond James Investment Services Limited, Raymond James Financial International Limited, Raymond James Global Holdings Limited, CSG and CSC (each an “RJUK entity”, and together “RJUK”)
The publication of this UK Tax Strategy is considered to fulfill RJUK’s obligation under paragraph 22(2) of Schedule 19 of the Finance Act 2016. It applies to each RJUK entity and applicable UK taxes.
This strategy is reviewed and updated annually. The board of directors of each RJUK entity approve it.
Introduction
The RJUK entities are ultimately owned by Raymond James Financial Inc., a US publicly traded company listed on the New York Stock Exchange. RJUK’s tax strategy is based on policies, procedures and controls that are compliant with all applicable UK tax legislation. We seek to ensure that we pay the appropriate amount of UK tax, and that UK tax returns and payments are accurate and made on time.
Risk management and governance arrangements
RJUK assesses, mitigates and manages risks, which is vital to our business strategy and includes tax risks. All business strategies, including tax, are led and overseen by the senior management of RJUK, and ultimately overseen in the UK by the boards of the RJUK entities. Day to day responsibility is delegated to the CFO of the entity with support and collaboration across all jurisdictions, utilizing external local country advisers where required. External tax advice is also sought where the tax treatment of transactions is complex, unclear or uncertain under UK tax law.
Where elements of the tax strategy straddle our global businesses, leadership resides with the US parent’s tax function, with appropriate input and collaboration from overseas individuals as required. This includes transfer-pricing agreements for intercompany transactions to ensure they are completed at arm’s length pricing and reflects business and commercial realities in accordance with OECD guidelines.
The Group’s board has a conservative appetite for tax risk. While eliminating tax risk is unattainable, RJUK’s attitude towards the level of control required over the processes designed to reduce these tax risk is driven by the firm’s very conservative approach to risk management.
RJUK does not tolerate tax evasion or the facilitation of tax evasion.
Tax planning
Tax consequences of transactions are considered as part of RJUK’s overall business decisionmaking process, but transactions are driven by economic substance and a valid business purpose rather than tax mitigation motives. RJUK does not implement or employ any aggressive or marketed tax avoidance strategies or artificial structures. RJUK’s aim is to ensure that its tax position in any planning activity is consistent with the spirit as well as the letter of tax law. All transactions have an underlying commercial substance and any related tax planning arrangements are in line with our tax strategy and conservative tax risk appetite. In accordance with OECD guidelines, all the intercompany transactions between group entities are conducted on arm’s length principles.
Tax appetite
RJUK has a conservative appetite for tax and regulatory compliance risk. Our conservative risk appetite is set by the senior management of the entity and driven by our reputation as a leading financial services firm, in which context tax or regulatory failings could have a material adverse effect on our reputation and relationship with HMRC and key stakeholders (including shareholders, employees and clients) and our business. We consistently work to lower the risk and uncertainty in complex transactions by seeking appropriate external advice and engaging directly with regulatory bodies worldwide, including HMRC.
RJUK is committed to adherence to all relevant UK tax legislation. This also ensures that we identify, assess and mitigate UK tax risks effectively.
Working with HMRC
We are committed to being compliant with all UK statutory obligations, filing requirements and/or tax disclosures with UK HMRC. We aim to maintain a strong professional relationship with HMRC and are transparent in our dealing with HMRC and proactive in discussing any issues of concern, as appropriate. Our relationship with HMRC is guided by our core values and high standards of business conduct. We work collaboratively wherever possible with HMRC to resolve disputes and obtain certainty in relation to UK tax risk, the UK tax treatment of proposed business transactions and the interpretation of UK tax law.
Black MondayOn 19 October 1987, the stock markets experienced a dramatic plunge that prompted many firms to shut down their trading desks and turn off their phones to minimize internal losses. Raymond James refused to do the same. Our desks stayed open to help meet clients’ needs, resulting in our first and only unprofitable quarter since the firm went public in 1983. |
 |
Who was Raymond James?The Raymond in our name is actually from Edward Raymond, owner of a 15-employee mutual fund sales group, Raymond and Associates, along Florida’s west coast. He sold his company to Bob James on 15 July 1964, on condition that the surviving firm be called Raymond, James & Associates. Three days after the sale, Ed Raymond was involved in a near-fatal automobile accident and never joined the firm. Nonetheless, even after Raymond had passed away, Bob James insisted that his name remain on the door – ahead of James’ own. That was a promise he made to Ed Raymond three days before the accident, and Bob James was a man who kept his promises. |
|
Bear Market of 1974The severe bear market of 1974 threatened the existence of Raymond James, which was bleeding capital by the day. Tom James, his father and other leaders took extreme measures to keep the firm afloat, slashing costs, foregoing paychecks and even attempting to sell the firm for just enough capital to protect client assets and retain as many associates as possible. The story could have ended very differently if not for a sharp upturn and continued rebound in the stock markets late in the year. |
|
Taking Raymond James PublicWhen consideration was being given to taking Raymond James public, Tom James penned a letter to shareholders (largely employees at the time). ” … the public offering should be considered as a statement of our independence. While this is a psychological rather than an economic rationale, it is nonetheless very important. We have asserted for some time that we are not interested in becoming a small part of a very large corporation. That assertion results mainly from the inclinations of management rather than the economic benefits associated with either alternative. The public stock offering affords us the opportunity to enjoy a little bit of the best of both worlds. While shareholders will be given liquidity at fair market value, we will still have the ability to control our own destiny.” After 40+ years of Tom’s leadership, upon becoming CEO, Paul Reilly was often questioned about whether the company might ultimately surrender its cherished independence and be acquired by some larger entity. His response: “Not while I’m around.” It’s a theme that continues today. |
 |
