Contents

1. Introduction
2. Tax Strategy Objectives
3. Approach to Risk management and Governance in relation to UK Taxation
4. Attitude towards tax planning
5. Level of risk in relation to UK taxation
6. Approach to dealings with HMRC

1 Introduction

This tax strategy document (the ‘Tax Strategy’) sets out the standards the Board of Uniserve Holdings Limited (the ‘Board’) applies in respect of the management of UK taxes and the framework of governance it employs to ensure those standards are embedded throughout the group.

This Tax Strategy is applicable to Uniserve Holdings Limited and its subsidiaries (the ‘Group’) and all of the Group’s employees engaged in the management and administration of tax.

For the purposes of this document ‘tax’ includes: Corporation Tax; Employment Taxes; National Insurance Contributions; Customs and excise duties; VAT; Stamp Taxes as well as any other taxes which the Group has a statutory obligation to manage.

This tax strategy has been prepared in accordance with the requirements of Section 161 and Schedule 19 of Finance Act 2016 and we regard this as fulfilment of our obligations therein; specifically in respect of s.19(2) of Schedule 19 FA 2016.

2 Tax Strategy Objectives

The Group has several key tax objectives:

Compliance – The primary focus in respect of tax is on compliance with the tax legislation which includes paying all taxes due on a timely basis.

Risk – To ensure that tax is considered in all significant business decisions which allows the Group to understand and manage the risks associated with such decisions and transactions.

People – To have the right people, processes, and systems in place to uphold our tax strategy objectives.

Behaviour – Employees responsible for dealing with tax authorities are expected to always behave honestly, openly and in a collaborative way.

Tax Planning – The Group’s reputation and integrity is of paramount importance, as such we will not engage in behaviours that may bring the Group into disrepute. We will not participate in tax schemes which seek to exploit perceived loopholes in the tax legislation.

Tax Reliefs – To remain competitive within our industry we will ensure that we consider all relevant government tax incentives and reliefs and will consult with external tax advisors where appropriate.

Transparency – Where we disagree with HMRC on matters of a technical nature we will be open and transparent in all our dealings and take appropriate external advice as needed to seek to resolve such matters.

Knowledge – We will maintain relationships with external advisors to ensure that we receive appropriate support on uncertain areas and to ensure that we are aware of upcoming tax changes which may impact the Group.

3 Approach to Risk Management and Governance in relation to UK Taxation

The Tax Strategy is approved by the Board and is owned by the Managing Director who is a member of the Board, ensuring that tax is represented in all significant business decisions taken by the Board. The Managing Director is also the Senior Accounting Officer (“SAO”) who is responsible for managing the overall tax relationship with HMRC.

Operational tax responsibility is delegated to members of the Finance Team who report to the Managing Director to ensure timely and accurate submission of the group’s tax returns and associated tax payments. It is the responsibility of the individual members of the Finance Team to comply with the policies and procedures established, and our SAO works closely with the Finance Team to ensure tax compliance through appropriate planning and review.

The strategy is considered annually for ongoing relevance and to reflect material changes either in tax legislation or the nature of the business that requires the policy to be updated.

To ensure that tax is considered by those persons within the Group who hold senior positions, open and regular communication is expected between the Finance Team and those individuals.

Those with responsibility for Risk management and Governance are expected to ensure that they, or members of their teams, receive appropriate updates on relevant tax developments and they should seek tax input for all significant commercial transactions. When necessary, we will consult with external tax advisors to ensure that we comply with all aspects of tax legislation.

Risk Management – The Group aims to achieve its tax objectives through:
1) Ensuring the IT systems that are in place to capture the data, which feeds into the tax returns, are robust and continually monitored and updated where necessary.

2) Strong tax compliance procedures to ensure the tax returns which are prepared are accurate and complete.

3) Review processes by appropriately qualified individuals, in respect of all tax returns which are submitted to HMRC.

4) Ensuring documentation is maintained to provide factual support to all tax returns submitted.

5) Utilising appropriately qualified individuals to deal with the various different taxes which the Group is responsible for.

6) Involving appropriate tax specialists in significant business decisions and engaging in regular dialogue with HMRC and being transparent in all such dealings. The Group is committed to maintaining a close relationship with external advisers and engaging with them where there are complex technical areas which require specialist knowledge and experience which are non-routine.

7) Monitoring introduction of new tax legislation or significant changes to existing tax regimes which are material for the Group.

4 Attitude towards tax planning

The Group’s reputation and integrity is of paramount importance, as such we will not engage in tax planning that may bring the Group into disrepute. Tax planning is focused around ensuring the Group is fully aware of the implications of carrying out business transactions and taking steps to reduce tax costs in line with the intention of the tax legislation and ensuring that all appropriate statutory tax reliefs are claimed.

5 Level of risk in relation to UK taxation

The Group’s reputation and integrity is of paramount importance and the Group does not seek to engage in tax planning which is contrary to the spirit of the tax legislation. The Group adopts a low level of risk in relation to UK taxation.

Whilst recognising that tax risk cannot be completely eliminated, the Group adopts a proactive approach to dealing with tax risk. This is carried out through a continual process of identification, evaluation and reporting of tax risks, as noted in 3 above, and the use of external advisors. This is carried out in the context of the type of taxes borne and collected by the Group and considering the quantum of those taxes.

6 Approach to dealing with HMRC

Overview

We aim to have an open and collaborative working relationship with HMRC reflecting the Board’s emphasis on compliance and good governance. We will respond to all reasonable requests for information by HMRC on a timely basis. In any interaction with the tax authorities, our employees are expected to behave courteously, honestly and with integrity.

Tax Compliance

We are committed to complying with all applicable laws and regulations. In the context of tax, this commitment comprises the following:

Payments – To pay all taxes which we are legally obliged to pay as and when they become payable.

Legislation – To comply with all relevant tax laws and regulations and the spirit of these laws.

Returns – Submit all tax returns on a timely basis, with full disclosure and to engage with HMRC to discuss any major items of uncertainty should these exist.

Review – Ensure all tax returns are reviewed by someone other than the preparer with sufficient technical expertise to carry out that review.

Openness – Promptly report any detected material errors or omissions in tax returns that have been filed.

Enquiries – Respond to tax enquiries in an open, honest, and timely manner.

Disputes – If any disputes regarding the interpretation of tax law arise, we will take a transparent and honest approach with HMRC and ensure that appropriate information is shared with HMRC to seek to reach agreement, wherever possible. If such agreement is not reached, we shall follow the processes laid out within the tax legislation, including, if required, due legal process to clarify the tax law in dispute.

Documentation – Maintain all relevant documentation in relation to the tax returns submitted for the appropriate amount of time required.

Reviewed by the Board: September 2024
Next review date: By October 2025