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Tax Strategy Publication

Curtis Banks Group plc (“the Group”)

Tax Strategy Publication

Year ended 31 December 2017

The Group regards this publication as complying with its duty to publish its tax strategy for the year ended 31 December 2017 in accordance with current tax legislation.

It is the Group’s policy to comply with HMRC rules concerning all forms of taxation while taking advantage of accepted and efficient practices for minimising the cost to the business. The Group does not take part in any tax avoidance schemes. The Group takes specialist advice from its external tax advisers as and when appropriate.

The Group’s Chief Financial Officer takes overall responsibility for ensuring the Group’s compliance with all taxation rules and regulations, and reports back to the Group’s Board of Directors as appropriate. Close contact is kept with the Group’s external tax advisers and also monitoring on a regular basis of the actions of the internal teams under the Chief Financial Officer. In place are detailed sets of systems, procedures and controls covering all aspects of how the business is run from a financial point of view, including tax matters where relevant, to ensure that the Group’s level of tax risk remains at acceptable levels.

Corporation tax is a significant cost to the Group and it instructs external tax advisers to advise on corporation tax matters. Advantage is taken of group relief for losses, capital allowances on eligible capital spend and relief for share scheme deductions where applicable. The Group also carefully examines all potentially disallowable expenditure for items such as business entertaining to ensure the correct disallowance of the relevant amounts are identified.

With regard to PAYE and National Insurance, the Group operates standard practices for its payroll. In the case of benefits in kind these are carefully monitored and reported to HMRC in the normal way.

With regard to VAT, the Group has in place detailed practices whereby transactions are carefully examined by its internal accounting team who is well versed and trained to ensure the correct VAT treatment. Certain parts of the Group have to account for VAT on both the Partial Exemption Method and the Capital Goods Scheme. Specialists in the Group carry out these calculations on either a monthly or quarterly basis so as to ensure the correct disallowance of the relevant amounts.

The Group has yet to be allocated a Customer Relationship Manager at HMRC. Accordingly, the Group and its external advisers (acting as agent for the Group) currently liaise with HMRC through more general communication channels.