John Cotton Group presents its UK Tax Strategy.

Introduction

In accordance with the requirements of paragraph 16(2) of Schedule 19 of the Finance Act 2016, John Cotton Group presents the Group’s UK Tax Strategy for John Cotton Group Limited and its UK subsidiaries (“UK Group”) for the year ended 2 March 2025.  This tax strategy applies to all UK taxes applicable to the UK Group and has been approved by the Board of Directors of John Cotton Group Limited (“the Board”).

The policy will be reviewed annually.

Approach to risk management and governance arrangements

The UK Group has a low appetite towards tax risk and as such all significant tax decisions are agreed by the Group Financial Controller, Group Company Secretary and the Chief Financial Officer and reviewed, monitored and endorsed by the Board.

The UK Group has clear tax policies, procedures and controls in place to meet the obligations of the Senior Accounting Officer legislation and are assessed through a central risk register.  These are overseen by the Group Financial Controller, Group Company Secretary and Chief Financial Officer, and are monitored and reviewed by internal teams and tax specialists.

As part of the continuous review of controls and procedures, the Finance team examines areas of the business and its processes, including tax.

External tax advisors are on hand to provide tax advice and confirmation where required, for example when new legislation is introduced or on areas of uncertainty.  External tax advisors also review the UK Corporation tax returns before they are filed with HMRC.

Attitude towards tax planning

When entering into commercial transactions, the UK Group seeks to take advantage of available tax incentives, reliefs and exemptions which are consistent with the spirit as well as the letter of the tax law and takes external advice to confirm this if necessary.

The UK Group’s policy is to not enter into any artificial tax planning arrangements that are not underpinned by a commercial transaction.

The level of risk in relation to UK taxation

The UK Group seeks to comply fully with its regulatory obligations and ensures the tax arrangements are consistent with a low tax risk approach to conducting its business.

The UK Group does not seek to structure transactions in ways that give tax results inconsistent with their underlying economic consequences.

Where the tax treatment of any particular material transaction is uncertain, external tax advice will be sought before proceeding with the transaction.

The approach towards dealings with HMRC

The UK Group’s approach to HMRC is transparent and constructive, resulting in a positive working relationship.  The UK Group takes the initiative to raise with HMRC any doubtful or contentious issues.

The UK Group engages on a real-time basis with HMRC to ensure compliance and create certainty for the UK Group in respect of payroll taxes, indirect taxes of VAT and Customs duties. This proactive approach helps the UK Group to comply with the HMRC requirement of “right duty at the right time”.

Published date: 22 October 2024