Tax Governance and Risk Management

The Group’s objectives in managing and controlling its tax affairs and related tax risks are as follows:

ensuring compliance with all applicable rules, legislation and regulations in the jurisdictions in which it operates
paying the correct amount of tax as it falls due.
Tax policies and risks are assessed for each new transaction and on an on-going basis for changes in legislation. Tax policies and risks are reviewed regularly by the Group’s Finance Director, with support from external tax advisors.

We have a tax control framework in place to manage our tax risks. The controls are monitored frequently to ensure they are operating effectively.

We employ individuals with appropriate tax knowledge and experience to manage tax risks and to ensure compliance. The Group takes appropriate tax advice from reputable professional firms.

Attitude to Tax Planning

Tax as a business expense is managed like any other cost and the Group utilises legitimate tax incentives or opportunities for obtaining tax efficiencies. The Group only undertakes tax planning which is aligned with a genuine commercial rationale.

Tax Risk Appetite

Significant tax risks, implications arising from these risks and potential mitigating actions are considered by the Board when strategic decisions are taken – the tax risks of proposed transactions or new areas of business are fully considered before proceeding.

We have a low appetite for tax risk which can be defined as not undertaking any transactions involving tax that are not fully supported by commercial activities.

Working with HMRC

The Group maintains a co-operative and pro-active relationship with the UK Tax Authorities to encourage an open relationship and hence to reduce our risk profile.

Where any tax law is unclear or subject to interpretation, we will engage with external tax advisers to ensure we remain compliant and to share our view with the tax authorities as applicable.

This tax strategy relates to the accounting year ended 30 September 2017 and has been prepared in accordance with Schedule 19 of the Finance Act 2016.’ The strategy was approved by the Board on 25 September 2017.