Allfunds Data Analytics Limited is a private company limited by shares incorporated in England and Wales. The registered office is 2 Fitzroy Place, 8 Mortimer Street, London, W1T 3JJ.
The financial statements are prepared in sterling, which is the functional currency of the company. Monetary amounts in these financial statements are rounded to the nearest £.
The gain or loss arising on the disposal of an asset is determined as the difference between the sale proceeds and the carrying value of the asset, and is credited or charged to profit or loss.
Basic financial assets, which include debtors and cash and bank balances, are initially measured at transaction price including transaction costs and are subsequently carried at amortised cost using the effective interest method unless the arrangement constitutes a financing transaction, where the transaction is measured at the present value of the future receipts discounted at a market rate of interest. Financial assets classified as receivable within one year are not amortised.
Financial liabilities and equity instruments are classified according to the substance of the contractual arrangements entered into. An equity instrument is any contract that evidences a residual interest in the assets of the company after deducting all of its liabilities.
Basic financial liabilities, including creditors, bank loans, loans from fellow group companies and preference shares that are classified as debt, are initially recognised at transaction price unless the arrangement constitutes a financing transaction, where the debt instrument is measured at the present value of the future payments discounted at a market rate of interest. Financial liabilities classified as payable within one year are not amortised.
Trade creditors are obligations to pay for goods or services that have been acquired in the ordinary course of business from suppliers. Amounts payable are classified as current liabilities if payment is due within one year or less. If not, they are presented as non-current liabilities. Trade creditors are recognised initially at transaction price and subsequently measured at amortised cost using the effective interest method.
Equity instruments issued by the company are recorded at the proceeds received, net of transaction costs.
When the terms and conditions of equity-settled share-based payments at the time they were granted are subsequently modified, the fair value of the share-based payment under the original terms and conditions and under the modified terms and conditions are both determined at the date of the modification. Any excess of the modified fair value over the original fair value is recognised over the remaining vesting period in addition to the grant date fair value of the original share-based payment. The share-based payment expense is not adjusted if the modified fair value is less than the original fair value.
Cancellations or settlements (including those resulting from employee redundancies) are treated as an acceleration of vesting and the amount that would have been recognised over the remaining vesting period is recognised immediately.
The average monthly number of persons (including directors) employed by the company during the year was:
During the year, the company recognised total share-based payment expenses of £52,678 (2023 - £29,352) which related to equity settled share based payment transactions.
As the income statement has been omitted from the filing copy of the financial statements, the following information in relation to the audit report on the statutory financial statements is provided in accordance with s444(5B) of the Companies Act 2006:
The Organisation for Economic Co-operation and Development ("OECD")'s Model Rules (also known as the "Global Base Erosion Rules" or "GloBE Rules", hereinafter referred to as Pillar Two), aim to create a common framework to establish a global minimum level of taxation for multinational groups.
Affected groups are required to calculate their Effective Tax Rate ("ETR") for each country or territory in which they operate under the GloBE Rules. If this rate is below a minimum rate of 15%, as a general rule, the group will be required to pay a top up tax on the difference.
The Group operates in the United Kingdom, Spain, Brazil, China, France, Germany, Hong Kong, Italy, Luxembourg, Poland, United Arab Emirates, Singapore, Sweden and Switzerland. The Ultimate Parent Entity (“UPE” in the GloBE nomenclature) is Allfunds Group plc, located in the United Kingdom, where the UK Pillar 2 Law was implemented in 2023. The UK's Pillar Two rules apply for accounting periods beginning on or after 31 December 2023 and will apply in respect of profits in every jurisdiction where the Group operates. The Company qualifies as a Constituent entity of the Group plc for Pillar 2 purposes.
Therefore, Allfunds Group plc will be, under the primary rule established in the GloBE Rules, responsible for the top-up tax in relation to its operations and all its constituent entities, except in those countries where a Qualified Domestic Minimum Top-up Tax ("QDMTT") considered as a safe harbour has been approved. The OECD has provided certain simplification rules which allow for safe harbour on a transitional basis until 2026, while a more permanent safe harbour is being developed. In 2024, where a jurisdiction is not covered by transitional safe harbour provisions (detailed in the "Transitional CbC Safe Harbours"), they will be required to calculate the ETR according to the Pillar Two rules and to pay the relevant top-up tax if the ETR is below the 15%.
The Group assessed if the Transitional CbC Safe Harbours published by the OECD could be applicable for the year 2024 in each jurisdiction. Based on the financial information as at 31 December 2024, all jurisdictions except Switzerland meet at least one of the three tests. In Switzerland, a QDMTT was formally enacted in 2023, which is effective from 1 January 2024. This QDMTT has been deemed as a safe harbour by the OECD. In this sense, Allfunds Bank, S.A.U. Zurich branch will be liable for the eventual top-up tax in relation to its operations. The Group has carried out a detailed calculation of the Swiss QDMTT, in accordance with the GloBE Rules and Swiss Pillar Two legislation, based on the financial statements as of 31 December 2024. According to such an estimation, no Swiss QDMTT would be expected.
In this context, and to what refers to the Company, the deferred tax assets not recognized in its balance sheet are disclosed below:
Tax losses
The Branch has the following unrecognised tax losses from prior years, as the timing of their possible recovery is uncertain since it depends on future taxable profits being obtained:
Year Incurred Tax base amount (GBP)
Pre-2017 0
Post 2017 379,734
Total 379,734