TAX STRATEGY



INTRODUCTION

This tax strategy applies to all UK incorporated companies and UK resident establishments of the AllSaints group1 (“AllSaints”) and sets out AllSaints’ approach and attitude to UK taxation2; it is published in accordance with paragraph 16(2) of Schedule 19, Finance Act 2016.



TAX RISK MANAGEMENT AND GOVERNANCE

AllSaints’ Board of Directors (“the Board”) is ultimately responsible for the setting of, and compliance with, this tax strategy. The Chief Operating Officer (“COO”) has executive responsibility for tax; executive management is delegated to the Global Finance Director (“GFD”), who reports to the COO, and day-to-day management is delegated to the Global Tax Manager (“GTM”), who is appropriately qualified and who reports to the GFD.


The GTM regularly meets with the GFD to discuss tax and, as necessary, the GFD will discuss matters with the COO at their regular meetings. Where appropriate, in particular as regards informing the Senior Accounting Officer certification3, or complex, or specialist matters, the GTM will meet with the COO (or another Board member, e.g. the Chief Executive Officer, as appropriate) alongside the GFD.


The GTM seeks to identify and manage tax risks arising from AllSaints’ business operations by applying their knowledge and experience and endeavours to ensure that reasonable care is applied to controls and processes that could materially affect tax.


Specifically, the GTM: maintains the tax risk register for SAO certification purposes; monitors business and legislative changes that may impact tax risks and advises, as appropriate, on changes to be made to controls, processes or systems; engages with other AllSaints’ personnel that manage or process matters that affect tax and recommends, as required, relevant sources of assistance, knowledge or training, and engages with external advisers when needed.



TAX PLANNING

AllSaints does not undertake any aggressive tax planning, including the undertaking of any artificial transactions, the sole purpose of which is to reduce tax.


In conducting its business, AllSaints may claim any reliefs, e.g. allowances, deductions, incentives, exemptions, credits, etc., to which it is entitled, provided that the outcome of applying such reliefs is aligned with commercial and economic reality and is sustainable. Where appropriate, in particular as regards complex or specialist matters, written advice evidencing the facts, risks and conclusions may be sought from external advisers.



ACCEPTABLE LEVELS OF TAX RISK

Whilst AllSaints does not have defined levels of acceptable tax risk, consistent with its approach to corporate responsibility AllSaints takes a prudent approach to risk in relation to tax. The Board is ultimately responsible for identifying risks, including tax risks, and, having regard to all facts and circumstances, for determining how they are addressed.



RELATIONSHIP WITH HMRC

AllSaints is committed to maintaining an open, co-operative, professional and transparent relationship with HMRC and to work collaboratively therewith to resolve disputes and to achieve timely agreement and certainty.


In particular AllSaints endeavours to ensure that HMRC are made aware of any significant changes or transactions in its business. Where there is uncertainty as to the application or interpretation of legislation, or where the applicable legislation is complex, AllSaints may engage with external advisers, and, as necessary, will discuss the matter with HMRC at the earliest possible stage to gain certainty or to reduce the potential for future dispute.



Approved by the Board of Directors on 23 January 2018




1 Headed, as defined by paragraph 9, Schedule19, Finance Act 2016, by Lion/Heaven UK Ltd

2 Paragraph 15(1), Schedule19, Finance Act 2016

3 Paragraph 2, Schedule46, Finance Act 2009