Dogger Bank Wind Farm is an offshore wind farm being developed in three phases – Dogger Bank A, B and C – located between 130km and 190km from the North-East coast of England at their nearest points. Collectively they will become the world’s largest offshore wind farm. Each phase will have an installed generation capacity of 1.2GW and represents a multi-billion-pound investment. Combined, they will have an installed capacity of 3.6GW and will be capable of powering up to 6 million homes annually.
The day-to-day activities of each of Dogger Bank are carried out in the following legal entities (the “Companies”):
This document outlines the responsibilities and conduct expected of the Companies and has been formulated to not only support the objectives of a Tax Policy for Dogger Bank; but also to support each of the Companies regarding its publication required to comply with the duties under paragraph 16(2) of Schedule 19 of Finance Act 2016, for the year ending 31 March 2026.
These principles are approved by the Dogger Bank Board and enforce Dogger Bank’s commitment to be regarded as a responsible tax-payer.
Dogger Bank’s primary objective from a tax perspective is to be compliant with all tax legislation requirements. This includes making timely and accurate returns which reflect each of the Companies’ fiscal obligations to Government whilst, at the same time, recognising all legislative concessions and reliefs.
Each of the Companies strives to minimise its total tax liability within the framework of legislative reliefs but does not take an aggressive stance in its interpretation of tax legislation. Dogger Bank’s policy is to operate within the law at all times. Therefore, none of the Companies use artificial tax avoidance schemes or tax havens to reduce tax liabilities.
Central to Dogger Bank’s Tax Policy is the maintenance and development of a strong working relationship with HMRC based on trust and cooperation. As a consequence, the Company strives to be regarded as a low risk and responsible taxpayer.
Each of the Companies’ Board of Directors has ultimate responsibility for Dogger Bank’s Tax Policy. For each of the Companies, it is the obligation of the Senior Accounting Officer (“SAO”) to ensure compliance with the Tax Policy. Each of Dogger Bank A, B and C is a joint venture between SSE, Equinor and Vårgrønn. Each Projco is owned 100% by its respective Holdco and the shares in each Holdco are held by the joint venture parties; SSE Renewables Offshore Windfarm Holdings Limited (40%), Equinor New Energy Limited (40%), and North Sea Wind Limited (20%).
Under a Management Services Agreement (“MSA”) between the Company and SSE, SSE provides a finance team for Dogger Bank (the “Finance Team”) during construction of the project. The Finance Team has responsibility for all aspects of the Companies’ financial activities, including tax affairs. Under this responsibility, the Finance Team has appointed an external tax adviser to the Companies. The expertise of the tax advisers is utilised to enable the Finance Team to manage tax matters for the Companies and to fulfil the Companies’ tax compliance requirements. In addition to the services provided by the external tax adviser, SSE provides to the Companies under the MSA, limited scope services carried out by the SSE tax department. This includes assistance on areas such as the submission of the Company’s monthly VAT return.
The SAO and Finance Team discuss any uncertain or complex tax issues with the external advisers to manage the tax risk. Any uncertain or complex tax issues are discussed with relevant teams at each of the shareholders in the joint venture.
Diligent professional care and judgement is applied when considering tax risks in line with the Company’s overall approach to risk management. Treatment of any tax risks identified are well documented and supported by strong technical advice provided by the external advisers where appropriate.
The SAO and the Finance Team are kept up to date on any legislative changes which may impact the tax affairs of the Companies, through regular updates from the external tax adviser.
Dogger Bank has an obligation to operate the Companies efficiently, and to act in the best interests of its shareholders, through managing total tax liability. Those considerations are balanced with Dogger Bank’s duty to wider society to be a responsible corporate citizen. All tax decisions taken by the Companies consider relevant laws, regulations and the commercial substance of any transaction.
The Finance Team works closely with the wider Dogger Bank project team, to be kept fully informed of, and provide appropriate input into, all significant business transactions and activity. In advance of any significant transactions, the SAO and Finance Team will consider any potential tax consequences and discuss with the project team, as appropriate, to enable informed decisions. A tax efficient approach to the transaction will be recommended, whilst having regard to all relevant laws, regulations and the commercial substance of the transaction, and ensuring that it is consistent with Dogger Bank’s Tax Policy. All tax planning undertaken by the Companies must have a sound and genuine commercial rationale, and all business planning must take tax considerations into account. All tax planning must fully comply with Dogger Bank’s Tax Policy.
Dogger Banks’s primary tax objective is that the Companies operate in accordance with all relevant laws, rules, and regulations at all times. Central to that is being open, honest and transparent in all correspondence with tax authorities and other regulatory bodies, ensuring full disclosure is provided.
Internal compliance procedures are followed to produce accurate and complete tax returns which are submitted on time, and to ensure that each of the Companies meets its SAO obligations.
The SAO is informed of all necessary financial information to meet the SAO obligations including review of a log of tax compliance review activity.
The filing position taken on any significant items would be supported by adequate documentation, together with reasoned conclusions based on the legislation in force at the time of filing. Advice is sought from Dogger Bank’s external tax advisers, where tax issues are uncertain or complex.
Tax incentives will be utilised where appropriate to legitimately minimise each of the Companies’ tax liability in accordance with all applicable laws, rules and regulations.
Where there is any element of judgement in applying available incentives, professional judgement is applied, but an aggressive interpretation of the legislation is not adopted. This is in line with Dogger Bank’s Tax Policy, that each of the Companies complies with the law at all times.
The maintenance and development of a strong working relationship with HMRC should be based on trust and cooperation. Dogger Bank supports such a relationship by proactively engaging with HMRC where necessary, to explain key business transactions, to minimise tax risk and provide understanding of the approach taken. Dogger Bank encourages open and collaborative relations with HMRC, and the provision of full information in a timely manner.