Apollo Group Holdings Limited UK Tax Strategy for the year ended 31 December 2023

Apollo Group Holdings Limited is the parent entity of the Apollo Group. The principal activities of its subsidiaries are that of a specialist Insurer and Reinsurer, which provides services to and participates on Lloyd’s Syndicates. This tax strategy applies to Apollo Group Holdings Limited and its UK subsidiaries – see Appendix 1.

The Apollo Group is committed to being a responsible business and compliant taxpayer. Our tax strategy supports the way we operate, our culture and how we conduct business.

How the business manages UK tax risk

The responsibility for our tax affairs rests with our Chief Finance Officer who is a member of our senior executive team and director of Apollo Group Holdings Limited.

The day-to-day tax management is delegated to the Finance Director (Corporate), the Group Tax Manager and wider Finance team, who have a framework of governance and controls in place to manage tax risks. An annual review is conducted of the tax accounting arrangements of the group, to ensure best practice and mitigation of risks.

The Board are made aware of any contentious or complex tax issues and risks as they arise and specialist external advice is sought, where appropriate. The tax function keeps up to date with changes in legislation and reporting requirements by attending technical updates and continuing professional development.

The tax governance framework includes:
• Senior management review and oversight
• Policies and Procedures
• Robust processes and controls to minimise the risk of error
• Staff training and continuous professional development
• Engagement with external advisors and legal counsel for technical support and feedback

Tax returns are prepared by our appointed tax agents and reviewed by suitably qualified professionals, as well as senior management.
Management of employee related tax matters is delegated to the Chief of Staff and the Human Resources department, with support from the tax and finance team, where required.

Structuring our tax affairs

Management decisions of the group are based on commercial considerations only, which comply with anti-abuse legislation and do not seek to gain a tax advantage. We seek to utilise tax reliefs only as intended by Parliament.

External tax advisors are engaged to support on complex or uncertain transactions.

Our approach to risk

As a rapidly growing group, with increasingly complex tax and reporting requirements, we have a low tolerance for tax risk and tax planning, ensuring decisions are made for commercial benefit, not to minimise tax liabilities. The group engages advisers to provide specialist support where new or complex legislation is brought in, to ensure full understanding and compliance.

Approach of dealing with tax authorities

Apollo recognises the importance of a cooperative, open, and transparent relationship with HMRC and seeks to maintain effective communication when engaging with the authorities.

Where an error is discovered, full disclosure would be made as soon as practicable, and the Group would seek to make good any outstanding amounts as soon as possible.

Where possible, advance clearance and discussions would be sought with HMRC, in relation to complex or non-routine transactions.


This tax strategy has been reviewed and approved by the Apollo Group Board and regards its publication as complying with the duty under paragraph 16(2) Schedule 19 of the Finance Act 2016.

Appendix 1

• Apollo Group Holdings Limited (12878158)
• Apollo Partners LLP
• Apollo Syndicate Management Limited (09181578)
• Apollo Group Services Limited – dormant (12878151)
• Apollo MGA Limited (13079112)
• Cyrene Investments Limited (07039481)
• Cyrene Capital Limited (07036905)
• Apollo Underwriting No.3 Limited – dormant (07036893)
• Apollo Underwriting No.4 Limited (07036894)
• Apollo Underwriting No.5 Limited (07036897)
• Apollo No.8 Limited (11638013)
• Apollo No.9 Limited (11638026)
• Apollo No.10 Limited (12116622)
• Apollo No.11 Limited – dormant (12169527)
• Apollo No.14 Limited (12222510)
• Apollo No.15 Limited – dormant (12222508)
• Apollo No.16 Limited (12228253)
• Apollo No.17 Limited (12228254)
• Apollo No.18 Limited – dormant (12917583)