Asset 2

NLF Tax Strategy

Nuclear Liabilities Fund Limited (NLF) is incorporated as a limited liability company having its registered office in Scotland. The entire ordinary share capital of the company is owned jointly by the trustees of The Nuclear Trust. The A Special Redeemable Preference Share of £1.00 is held by the Secretary of State for Business, Energy and Industrial Strategy. The B Special Redeemable Preference Share of £1.00 is held jointly by EDFE Nuclear Generation Limited and British Energy Generation (UK) Limited. NLF has no employees and hence all functions, including tax advice and management, are outsourced to third party providers.

This tax strategy applies to NLF from the date of publication until such time as it is superseded. References to ‘tax’, ‘taxes’ or ‘taxation’ are to UK taxation and to all corresponding worldwide taxes and similar duties in respect of which NLF has legal responsibilities.


NLF is committed to full compliance with all statutory obligations and full disclosure to tax authorities. The company’s tax affairs are managed taking into account NLF’s need to safeguard its reputation with stakeholders and its high standards of governance.

Governance in relation to UK taxation

    • Ultimate responsibility for NLF’s tax strategy and compliance rests with the Board of the company;
    • Executive and day-to-day management of NLF’s tax affairs is delegated and outsourced by the Board to specialist tax advisers to manage in accordance with the guidelines set out below;
    • The Board, with support from its specialist tax and investment advisers, ensures that NLF’s tax strategy is one of the factors considered in all investments decisions taken.

Risk Management

Tax risk is reported on a periodic basis to the Board which is ultimately accountable for how tax risks are identified, managed and monitored in the business.

NLF employs various risk management processes to provide assurance that tax risks are appropriately monitored. This includes engaging with NLF’s tax advisers to provide support in providing a system of tax risk assessment and controls as a component of the overall internal control framework applicable to the firm’s own financial reporting system.

Attitude towards tax planning and level of risk

NLF manages risks to ensure compliance with legal requirements and ensure payment of the right amount of tax. When entering into investments, NLF seeks to take advantage of any available tax incentives, reliefs and exemptions in line with, and in the spirit of, tax legislation. In relation to any specific issue or risk in relation to implementation of any tax planning or incentives which has been identified and brought to the Board’s attention by its advisers, the Board is ultimately responsible for determining what actions should be taken to manage those risks.

Relationship with HMRC

NLF seeks to have a transparent and constructive relationship with HMRC. When submitting tax computations and returns to HMRC, NLF seeks to disclose all relevant facts.