This document is produced in accordance with the requirement under Section 161 and paragraph 16(2) Schedule 19 Finance Act 2016 for the Dave Whelan Sports Limited group (The Group) to publish its UK tax strategy and sets out the group’s approach to tax. This strategy applies to all Dave Whelan Sports Ltd group entities.
It is not designed to be an operational manual with detailed instructions on the execution of the tax processes and controls.
This strategy applies to the taxes and duties in the UK which include:
o All corporate income taxes
o Indirect taxes (VAT, Stamp Duty Land Tax)
o Employment taxes (PAYE / National Insurance / Construction Industry Scheme)
o Other applicable tax matters
The tax strategy is approved by the Board and sets out our general tax arrangements as well as the policy and approach to tax risk management, attitude to tax planning and working with HMRC adopted by all Group members and employees.
ACCOUNTABILITY AND GOVERNANCE
The Finance Director and Finance Reporting Team are responsible for management of the tax affairs of Dave Whelan Sports Ltd and its group entities.
The tax affairs of the Group are managed by a team of suitably qualified financial professionals, supported where appropriate by external advisors. Training is provided where necessary to employees to ensure tax compliance is carried out with a suitable level of diligence and technical expertise.
The processes and controls which support the delivery of the tax strategy are regularly reviewed by the group Finance Director and members of the Board, while this tax strategy is reviewed annually.
The Group aims to pay the correct amount of tax, at the right time. We ensure compliance with all laws and relevant regulations, and make full and timely disclosures in tax returns, reports and documents submitted to taxing authorities (HMRC).
We do not accept or tolerate the criminal evasion of any taxes, or the deliberate and dishonest facilitation of another’s tax evasion, whether carried out by an employee or any other associated business partner acting for us, or on our behalf. We will not conduct business with anyone we believe is engaging in such practices.
We prepare and maintain all documentation required by law to provide support for a transaction with a tax impact.
ATTITUDE TO TAX RISK AND PLANNING
Where there is an uncertainty regarding tax law, we seek assurance either from third party advisors/advance assurance from HMRC if possible.
The Group does not enter into any contrived arrangements or schemes which would be disclosable under the DOTAS or GAAR regulations.
In making commercial decisions we take tax into account in the same way as any other cost. Where there is more than one way of structuring a commercial business arrangement we will take a holistic view, considering all factors including tax. Where alternative structures are available, the Group may choose to implement the structure with a lower tax cost. However this is only on the basis that structure is compliant with the relevant laws and regulations, and provided full and timely disclosures are made to HMRC.
All entities within the Group are UK resident. We do not use companies in tax havens as defined by the OECD, or any other overseas territory, to avoid taxes on activities which take place elsewhere.
We do not use contrived or abnormal tax structures that are intended for tax avoidance, have no commercial substance and do not meet the spirit of the law.
The Group does not artificially transfer profits from one business entity to another to avoid taxation. We aim to pay an appropriate amount of tax according to where value is created within the normal course of commercial activity.
WORKING WITH HMRC
It is the Group’s policy to be transparent and proactive in all interactions with HMRC.
We aim to have an open, honest and positive working relationship with HMRC, and are committed to prompt disclosure and transparency in all tax matters. Where an area of differing legal interpretation between ourselves and HMRC occurs, we will proactively engage in discussions to bring matters to as rapid a conclusion as possible.
All areas of uncertainty for taxation are fully disclosed to HMRC. Any inadvertent errors in submission of tax returns and tax computations for corporation, indirect taxes, and PAYE to HMRC are fully disclosed as soon as reasonably practicable after they have been identified.
29 March 2019