In compliance with Schedule 19 of the Finance Act 2016, this document sets out the policy and approach taken by Lookers plc and its subsidiary undertakings (“the group”) in conducting its tax affairs for the accounting period ended 31 December 2022.
This document is reviewed annually by the Group Tax Manager, Group Financial Controller and Chief Financial Officer and is subsequently approved by the Board of Directors.
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.
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 of Directors. The Chief Financial Officer has overall responsibility for the delivery of the strategy and delegates the implementation to the Group Tax Manager. Meetings of the Audit and Risk Committee also include discussions on any significant tax matters.
Tax risk management
The group is committed to complying with all applicable tax laws and financial reporting requirements. To do so, the group maintains a register of key tax risks, which are prioritised according to the significance and likelihood of the risk occurring.
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 would be adapted accordingly if necessary. Any material risks identified would be notified to the Audit and Risk Committee.
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 will be given to the capability of the third party and data will be 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 will be subject to rigorous testing.
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 shareholders 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
The group has adopted an open, honest and collaborative approach to its relationship with HM Revenue & Customs. The group engages with HM Revenue & Customs with integrity and transparency in relation to all tax matters. Returns are submitted and information requests are replied to in a timely manner. HM Revenue & Customs would be notified of any significant transactions in the regular on-going dialogue between the group’s Customer Compliance Manager and the Group Tax Manager.
Should any uncertainty or difference of opinion arise in relation to the interpretation of tax legislation the group will strive to reach an early agreement on disputed matters in order to achieve certainty wherever possible and advise HM Revenue & Customs of the filing position taken.
Updated and approved: 16 December 2022