Scope

The publication of this UK Tax Strategy statement is regarded as satisfying the statutory obligation under Para 19(2), Schedule 19, Finance Act 2016. “The Group” refers to all UK entities within the John Henderson (Holdings) Group of companies.

Overview of Internal Governance

The Group’s tax strategy, which covers both the internal governance of tax matters and the approach to tax, is approved by the Holdings Board on behalf Group Boards.

Tax is primarily the responsibility of the Group Finance Director who reports to the Chief Financial Officer who sits on the Holdings Board. Day to day tax matters are delegated to the Financial Controllers across the Group and a team of in house professionals who hold a combination of qualifications and experience appropriate to their roles and the assigned tax responsibilities.

The Chief Financial Officer and Group Finance Director hold regular meetings with external tax professionals to ensure the Group continues to comply with best practice.

The Group Finance Director in conjunction with the Financial Controllers across the Group ensure that adequate controls are in place so that the correct amount of taxes are identified and paid on a timely basis.

Approach to risk management

All Board meetings are attended by either the Chief Financial Officer or Group Finance Director and there is a standing item to provide any updates on significant tax risks and developments.

An internal procedures document maintained by the Group Finance Director outlines the tax compliance procedures, controls in place and the role of the person responsible for them.

All senior members of the Finance team attend external seminars on a regular basis to ensure full awareness of tax developments and internal seminars drawing on external expertise are run as required.

The Group has an internal audit function.

The Group has a low risk attitude in relation to tax and seeks to minimise the risk of uncertainty or disputes.

Attitude to tax planning

The Group is predominantly made up of UK businesses and all taxes are paid in the appropriate jurisdictions.

The Group has a responsibility to its shareholders to deliver value but will only engage in reasonable tax planning that is aligned with commercial and economic activity. Tax will be paid as appropriate in the jurisdiction that commercial activities take place. Tax will be a result of business strategy but will not drive business strategy.

The Group will not be structured to generate profits in favourable tax jurisdictions unless there are genuine commercial reasons for being in those tax jurisdictions. The Group will not enter into transactions that have a main purpose of gaining a tax advantage or make interpretations of tax law that are opposed to its original spirit.

The Group will only acquire businesses for strategic purposes and not to take advantages of tax opportunities such as tax losses. New companies will only be located in the tax jurisdiction where there will be genuine commercial activity and not because of the tax regime in that jurisdiction.

Relationship with HMRC

An important part of the Group’s tax strategy is to maintain and develop it’s strong, positive and transparent relationship with HMRC. The Group maintains an open dialogue with HMRC via regular meetings with the Group’s Client Relationship Manager and provides information on business activities, results and key developments as they arise. The Group proactively seeks the views of HMRC on any uncertain tax matters.

This document, approved by the board of The Group, sets out the Group’s approach to conducting its tax affairs and dealing with tax risks for the year ending 31 December 2018.