The purpose of this Tax Strategy is to communicate the Group’s policy for the management of tax. It is important to ensure that consistent and effective tax standards are maintained across the Group, as tax (both direct and indirect) can have a significant cash and profit & loss impact on many of the Group’s business activities.
This strategy applies to Wynnstay Group Plc and its subsidiaries in accordance with paragraphs 19 and 25 of Schedule 19 to the Finance Act 2016 (“the Schedule”). In this strategy, references to “Wynnstay” or “the Group” are to all these entities. The strategy is being published in accordance with paragraph 16(4) of the Schedule and is published in reference to the financial year ending 31 October 2022.
This strategy applies from the date of publication until it is superseded. References to “UK Taxation” are to the taxes and duties set out in paragraph 15(1) of the Schedule which include amongst others, Income Tax, Corporation Tax, PAYE, NIC, VAT, Insurance Premium Tax, and Stamp Duty Land Tax. References to “tax”, “taxes” or “taxation” are to UK taxation. Wynnstay operates solely within the United Kingdom and as such considers its tax strategy in this context.
Wynnstay is committed to full compliance with all statutory obligations and full disclosure to relevant tax authorities. Wynnstay believes that a coherent and responsible approach to Tax Governance is an essential element of its sustainable business development.
Wynnstay’s aim in relation to its tax affairs is to manage them in a fair manner which ensures compliance with all relevant laws, regulations and fiscal obligations in the UK, and which upholds the spirit of such obligations whilst protecting shareholder value. The Group is committed to the effective, sustainable and active management of its tax affairs in support of outstanding business performance. The Group actively endeavours to develop and sustain good and honest working relationships with His Majesty’s Revenue & Customs tax authorities (“HMRC”), to facilitate the smooth and honest compliance with its fiscal obligations.
Governance in relation to UK taxation:
Ultimate responsibility for Wynnstay’s tax strategy and compliance rests with the Board of Wynnstay Group Plc. As such the Board of Directors (“the Board”) have adopted an Active Engagement Tax Policy, which they would define as, a systematic and consistent declaration of all taxes to match the underlying activities of the Group, with all business decisions being based on prioritising genuine commercial criteria over taxation implications.
While Tax is one of the factors considered in all investment and significant business decisions, the Board will prioritise the commercial elements of such decisions, and as such the Tax Governance framework for the Group is suitable for delivering the desired objectives within a resource commitment appropriate for the activities and scale of the Group. Such resource and its operation will be kept under regular review, and no significant changes to this framework have occurred in the year to October 2022.
The Finance Director is the Board member with executive responsibility for tax matters and has ownership of the Group’s tax operations and oversight of tax risk, with the detailed analysis and preparation of the tax records being the responsibility of the Group Financial Controller and other suitably qualified members of the Group’s finance teams. The Group retains the services of external tax advisors to support the accurate preparation and submission of applicable tax returns. The Board’s Audit Committee includes taxation within its remit, including the monitoring of the effectiveness of internal financial controls applicable to taxation matters. A number of tax-sensitive processes are performed within the finance and human resources departments of the business and each relevant stakeholder is responsible and accountable for meetings its tax obligations.
Effective risk management is paramount for the Group and underpins its business strategy. Wynnstay seeks to reduce the level of tax risk arising from its operations as far as is reasonably practical by ensuring that reasonable care is applied in relation to all processes which could materially affect its compliance with its tax obligations.
In accordance with the Finance Act 2009 Schedule 46, the Group has appointed named Senior Accounting Officers for each subsidiary operating company, who are responsible for ensuring appropriate tax accounting arrangements are in place. Advice is sought from retained external advisors where appropriate.
The business will be independently audited annually, and tax accounting, where deemed appropriate, will be audited in accordance with this process. A plan of action will be agreed with the Finance Director and Group Financial Controller as applicable to act upon recommendations made as a result of such audits, within a timeframe appropriate to the Group’s risk management objectives and resource allocations.
Attitude towards tax planning and level of risk:
Wynnstay manages risks to ensure compliance with legal requirements in a manner which ensures payment of the right amount of tax. Wynnstay is committed to transparency in its Governance approach and its tax position. Statements and disclosures on its tax situation and tax payments should be made in accordance with relevant regulations, as well as the applicable reporting requirements according to international accounting standards such as IFRS adopted for the UK & OECD Guidelines.
The Group will refrain from the utilisation of any offshore secrecy jurisdictions or tax havens for tax avoidance purposes, and will not engage in the use of specifically constructed tax avoidance schemes or arrangements. The Group’s tax planning will be consistent with this responsible approach, with an aim to pay the appropriate amount of taxes according to value created in the ordinary course of the Group’s business activity.
Relationship with HMRC:
Wynnstay seeks to maintain a strong and mutually respectful relationship with the UK Tax Authority, based on the concept of openness and transparency outlined above. The Board have expressed, through the adoption of this strategy, an explicit intent to openly share all relevant and appropriate information with HMRC, and to work with the tax authorities in an honest and constructive manner. Wynnstay ensures that HMRC is kept aware of significant transactions and changes in the business and seeks to discuss any tax issues arising at an early stage. When submitting tax computations and returns to HMRC, Wynnstay discloses all the relevant facts and identifies any transactions or issues where it considers that there is potential for the tax treatment to be uncertain.
Any inadvertent errors in submissions made to HMRC are fully disclosed as soon as reasonably practical after they are identified.
Adopted by the Board of Wynnstay Group Plc
21 February 2023