Lookers Limited

Tax Strategy

Year ending 31 December 2024

Introduction

In compliance with Schedule 19 of the Finance Act 2016, this document sets out the policy and approach taken by Lookers Limited and its subsidiary undertakings (“the group”) in conducting its tax affairs.

This document is reviewed annually by the Head of Tax, Group Financial Controller and Chief Financial Officer and is subsequently approved by the Board of Directors(the Board).

References to tax include all forms of direct or indirect tax charges paid by the group including corporation tax, VAT, payroll taxes, import taxes and stamp duty land tax. The tax strategy applies to all entities within the group as well as all directors and employees whose actions or responsibilities impact on the management of tax.

Tax governance

The group is committed to applying diligence and care in its tax management processes and procedures and ensuring that tax governance is appropriate, with accountability for the tax strategy resting with the Board. The Chief Financial Officer has overall responsibility for the delivery of the strategy and delegates the implementation to the Head of Tax. The Board considers all significant tax matters relevant to the activities undertaken by the group.

CONFIDENTIAL

The group’s risk management framework incorporates processes and procedures which aim to minimise these risks and identify areas of potential non-compliance. These processes include risk monitoring reports and systems and reviews of tax compliance activity. Changes or updates to tax legislation are monitored and the group’s processes and controls are adapted accordingly if necessary. Any material risks identified are notified to the Board.

The tax function is embedded in the finance team and wider business so that tax implications are considered as part of real-time business decision making. External professional advice may be sought to support the group’s decision-making process, where this is considered appropriate, particularly for areas of complex tax legislation. Where the submission of information to the tax authorities is outsourced to a third party, due consideration is given to the capability of the third party and data is checked prior to submission to the tax authorities.

Accounting and payroll systems and tax reporting packages employed by the group are industry standard and are recognised by HM Revenue & Customs. Where such software is developed in-house it is subject to rigorous testing.

Tax planning

Any tax planning carried out by the group is in support of the commercial activities of the business, ensuring that the group trades in a tax efficient manner whilst remaining compliant with all relevant legislation. The group does not undertake tax planning which HM Revenue & Customs consider to be aggressive, and the group is not involved in the implementation of any schemes which are notifiable under the Disclosure of Tax Avoidance Schemes (DOTAS) legislation.

The group has a responsibility to the shareholder to maximise tax incentives and exemptions which are available and for which specific provision is allowed within tax legislation, for example capital allowances and tax credits arising from expenditure incurred in relation to research and development.

Relationship with tax authorities

Any tax planning carried out by the group is in support of the commercial activities of the business, ensuring that the group trades in a tax efficient manner whilst remaining compliant with all relevant legislation. The group does not undertake tax planning which HM Revenue & Customs consider to be aggressive, and the group is not involved in the implementation of any schemes which are notifiable under the Disclosure of Tax Avoidance Schemes (DOTAS) legislation.

The group has a responsibility to the shareholder to maximise tax incentives and exemptions which are available and for which specific provision is allowed within tax legislation, for example capital allowances and tax credits arising from expenditure incurred in relation to research and development.

Updated and approved: 16 December 2024