Tax Policy
Our approach to tax.
How we meet our own tax obligations, and the controls we maintain to prevent our services being used to facilitate tax evasion.
Our commitment. RimonPay pays the tax it is required to pay, on time, and reports its tax position accurately and completely. We do not engage in tax evasion, we do not facilitate it, and we will not work with anyone who asks us to.
We distinguish clearly between tax evasion, which is a criminal offence and which we never accept, and tax planning, which is arranging your affairs within the law. RimonPay does not provide tax advice to merchants, and nothing in this policy or on this site is tax advice.
01Purpose and scope
This policy sets out how RimonPay manages its tax obligations and the controls it maintains to prevent the criminal facilitation of tax evasion. It applies to all personnel, contractors, suppliers and partners acting for RimonPay.
02Our tax obligations
We meet our tax obligations in every jurisdiction in which we operate, including:
- registering for, and paying, corporation tax on our profits;
- registering for and accounting for VAT on our services, and filing returns on time;
- operating PAYE, and accounting for income tax and National Insurance on salaries, correctly and on time;
- maintaining accurate accounting records, and filing all returns and reports by their statutory deadlines;
- complying with Making Tax Digital requirements for digital record-keeping and filing.
Our accounts are prepared in accordance with applicable standards and are reviewed by [confirm: an external accountant / auditor]. We take professional advice where our position is unclear, and we do not take an aggressive position on a doubtful point.
03Tax evasion, avoidance and planning
| Concept | Our position |
|---|---|
| Tax evasion | Deliberately concealing income or providing false information to pay less tax than is due. It is a criminal offence. We never engage in it, never assist it, and never turn a blind eye to it. |
| Facilitation of tax evasion | Helping another person to evade tax, whether knowingly or not. We maintain the controls in sections 4 and 5 to prevent this, and it is treated as a serious breach of this policy. |
| Tax avoidance | Arranging affairs to reduce tax within the letter of the law. We do not enter into arrangements whose main purpose is to obtain a tax advantage that Parliament did not intend, and we do not market or promote such arrangements. |
| Tax planning | Using reliefs and allowances as intended by law, and taking advice on genuinely commercial decisions. This is legitimate and we do it. |
04Preventing the facilitation of tax evasion
The Criminal Finances Act 2017 created a corporate offence of failing to prevent the facilitation of tax evasion. It applies to organisations of every size, and to both UK and foreign tax evasion. A defence is available where an organisation has reasonable prevention procedures in place, or where it was not reasonable to expect any.
RimonPay maintains the following prevention procedures:
- Risk assessment — we assess the risk of our services being used to facilitate tax evasion, considering our business model, our merchant base, the jurisdictions involved, and the parties we transact with. The assessment is refreshed at least annually.
- Proportionate procedures — we apply controls proportionate to that risk, including the checks described in our Anti-Money Laundering Policy.
- Due diligence — we carry out know-your-business checks on merchants, suppliers and partners, and we are alert to indicators of tax evasion, including unexplained cash flows, invoices that do not reflect the services described, requests to route funds through third parties, pressure to falsify records, and any request to describe a transaction inaccurately.
- Clear communication and training — all personnel receive training on recognising and refusing requests to facilitate tax evasion, and know how to escalate one.
- Monitoring and review — we monitor for red flags and review the operation of these procedures at least annually.
- Top-level commitment — senior management endorse this policy and take it seriously.
Any request to facilitate tax evasion is refused and reported to senior management immediately. It is a disciplinary matter and may be reported to the relevant tax authority or the police.
05Tax and the businesses we introduce
RimonPay is an introducer to card acquirers. We do not process payments, hold funds, or act as a payment intermediary. That means:
- we do not withhold, deduct or account for tax on your transactions;
- we do not advise you on the tax treatment of your sales, your VAT position, or your cross-border obligations;
- we do not report your transaction data to tax authorities as a payment processor or platform operator would;
- you remain responsible for your own tax registrations, filings and payments in every jurisdiction in which you sell.
Your settlement and transaction reporting arrangements are governed by your agreement with the acquirer.
[Confirm with your tax adviser whether any platform-operator reporting obligation, such as the OECD rules for digital platforms implemented in the UK, could apply to RimonPay’s activities. If it could, this section and your onboarding processes must be updated. Do not claim an exemption you have not confirmed.]
06VAT on our services
Our commission is paid by the acquiring partner. Where RimonPay is required to charge VAT on its services, it is charged in accordance with applicable law. Where a commission relates to a business customer outside the UK, the place-of-supply and reverse-charge rules may apply.
[Insert your VAT registration number, or confirm that you are not registered. Confirm the VAT treatment of your commission with your tax adviser, including any cross-border supply.]
07Jurisdictions, sanctions and compliance
We operate in all areas not subject to sanctions. We do not structure arrangements to avoid tax in any jurisdiction, and we do not use entities or accounts in jurisdictions that would obscure the identity of a party to a transaction. Where a jurisdiction’s tax or sanctions regime makes a relationship unlawful, we will not enter into it.
08Governance, training and review
Senior management owns this policy. The finance lead is responsible for our tax filings and for the prevention procedures in section 4. All personnel are trained on this policy. It is reviewed at least annually, and whenever our business, the law, or our risk assessment changes.
09Approval and contact
This policy is approved by senior management of RimonPay. Questions should go to sales@rimonpay.com.