Royal Caribbean Cruises Ltd. (“RCCL”) is a publicly traded cruise line company with worldwide operations. As the world’s second largest cruise company, RCCL operates four brands: Royal Caribbean International, Celebrity Cruises, Azamara Club Cruises, and Silversea Cruises. In addition, we have joint venture interests in Pullmantur Cruises and TUI Cruises.
RCCL is headquartered in Miami, Florida, but since 2010 has the head office of its international operations located in the United Kingdom (UK). The UK presence is comprised of three entities (hereinafter referred to as “RCCL UK”): RCL Cruises Ltd, RCL UK Ltd and RCL Investments Ltd, all incorporated and tax resident in the UK. Our UK operations can be grouped in two main activities:
RCCL chose to invest in the UK by opening its head office for international operations in Weybridge, England in 2010. RCCL UK has been a significant investor in the UK, creating hundreds of local jobs, providing training for its UK maritime and non-maritime personnel while contributing to several aspects of the local economy. As a committed investor to the UK maritime industry, RCCL UK has been able to enjoy the benefits of the UK tonnage tax regime, in particular the certainty that it provides us over our tax liabilities.
RCCL mission statement and values are the guiding principles followed by RCCL UK board who ensure the business is managed according to these principles. As part of these values, RCCL UK requires that its employees commit to act in the highest ethical manner while enhancing the well-being of the communities where our business is conducted.
Our approach to tax is summarized by our tax principles. In particular, RCCL will:
A key aspect of our corporation tax affairs in the UK relates to our election in the UK tonnage tax regime.
UK tonnage tax is a tax regime which was introduced by the UK Government and is designed to encourage shipping companies to base their shipping operations in the UK. It does so by providing a simple method of calculating the profits which should be subject to UK corporation tax and is based on the tonnage of the vessels operated rather than based on company profits.
In order to elect into and benefit from the tonnage tax regime, RCCL must meet a number of requirements which are strictly enforced by Her Majesty’s Revenue and Customs (“HMRC”). In particular, RCCL UK is required to make an economic contribution to the UK through the strategic and commercial management of our vessels in the UK.
The board of directors of RCCL UK recognizes the importance of maintaining robust tax compliance processes and considers it key to managing tax risk. Board members regularly discuss tax matters with the RCCL Corporate Tax Department and tax plays an important role in Board business decisions.
RCCL UK is very risk averse, and we adopt a conservative approach as regards to tax matters.
In order to ensure that we effectively comply with our UK tax compliance requirements, including those related to UK tonnage tax, RCCL UK has created a set of processes and controls that are regularly reviewed and maintained for the purposes of Senior Accounting Officer (SAO)1 compliance.
RCCL is committed to complying with all relevant laws and regulations in all jurisdictions where the group operates. Tax Management is performed through the RCCL Corporate Tax Department and in constant collaboration with the RCCL UK business and finance department to provide the guidance and advice needed to ensure compliance with tax laws and regulations, especially with those governing UK tonnage tax.
Tax planning opportunities must be approved by the Board and are evaluated with current tax rules in mind while taking the legislator’s intention into account. Where there is uncertainty as to the application or interpretation of the tax laws, appropriate written advice evidencing the facts, risks and conclusions will be obtained from third party advisers to support the decision-making process. RCCL UK does not engage in aggressive tax planning and does not enter into transactions for the sole purpose of gaining a tax benefit.
RCCL UK is committed to engaging in a transparent and proactive manner with HMRC. The company’s UK tax affairs, past and proposed operations are discussed in an annual meeting with HMRC. Furthermore, the company maintains an ongoing communication with HMRC to discuss and conclude on areas the application of legislation to our facts is uncertain, ensure compliance with UK tax laws and regulations, communicating changes to our business and tax affairs in advance to HMRC.
This document is published in accordance with paragraphs 19(2) and 22(2) of Schedule 19 of the Finance Act 2016 and relates to the accounting period ended 31 December 2019.
1 The Senior Accounting Officer (SAO) is the individual who is responsible for certifying to HMRC that our UK incorporated companies have appropriate tax compliance arrangements.