Hemingways Tax Strategy
This tax strategy has been prepared and published in accordance with paragraph 16 (2), Schedule 19, Finance Act 2016, on behalf of Hemingways Group Holdings Ltd and its subsidiary group companies (‘Hemingways Group’, ‘Hemingways’, ‘the Group’). The entities to which this tax strategy applies can be found at Appendix 1. This tax strategy is effective in respect of the 30 April 2024 accounting period and is effective until it is replaced.
Hemingways Group recognises that paying taxes arising from its activities is an important part of how it contributes to the society in which it serves. The Group’s tax contribution importantly extends beyond corporation tax and the collection of income tax and includes the payment of significant employer social security contributions. The tax strategy approved by the Board, is to sustainably minimise tax cost whilst complying with the law. In doing so, it ensures it acts in accordance with Hemingway’s core ethics and corporate social responsibility beliefs. The Group is committed in meeting all its legal requirements, filing all appropriate tax returns and making tax payments accurately and on time.
TAX GOVERNANCE & RISK MANAGEMENT
Hemingways has clear tax procedures in place which are overseen by the Group Finance Director (FD), which support tax compliance and aim to identify and minimize tax risk.
The Group’s finance team, led by the FD who also acts as the Group Senior Accounting Officer, is responsible for the implementation of the Group’s tax strategy. The FD informs senior management in relation to key tax matters. Members of the team have either appropriate professional qualifications or experience which reflect the responsibilities required for their roles in order to support tax compliance and escalate tax risk where necessary. Tax compliance and risk management are also supported by reputable professional tax advisors.
Hemingways manages its tax affairs in a proactive manner that seeks to maximise shareholder value. The Group does not enter into artificial arrangements that lack commercial purpose in order to secure a tax advantage. The aim is to ensure full compliance with all statutory obligations and as a consequence attempt to minimise risk wherever possible. [/vc_column_text]
TAX PLANNING
Hemingways recognizes that tax is inherent in many commercial transactions. The FD has a direct involvement and input in all material transactions and processes to ensure a clear understanding of the tax consequences of any decisions that are made and to support tax compliance.
The Group will not seek tax efficiencies if the underlying commercial objectives do not support the position or if the arrangements impact on the group’s reputation, brand, corporate and social responsibilities or future working relationship with HMRC. The group seeks only to structure commercial transactions in a tax efficient manner where permitted by law and within approved HMRC guidelines. The Group aims to ensure that its approach to tax reflects the intentions of Parliament (the Group does not enter into structured or contrived tax planning).
In situations where the tax guidance is unclear for decision making purposes, external advice may be sought to support the decision-making process.[/vc_column_text]
TAX RISK MANAGEMENT
Hemingways ability to control external factors that may impact tax risks varies and it works to minimise these risks. For example:New developing tax legislation is monitored and where it is relevant Hemingways will contribute and input to consultations issued by the tax authorities. When new or changed legislation is announced, the impact on the Group is assessed and active measures are taken to ensure there are adequate processes in place to comply with any change;
Tax risks in relation to compliance and reporting are managed by consulting mainly with professional advisers and the tax authorities and where necessary with industry groups to keep abreast of changes in tax legislation and compliance requirements; and
Risk in relation to tax in general is managed by the finance team and if a position is uncertain, the Group will obtain third-party advice in order to gain clarity or support and ensure the Group is compliant in accordance with legislation.
ENGAGEMENT & RELATIONSHIP WITH TAX AUTHORITIES
Hemingways approach to its tax affairs is to have an honest and collaborative relationship with the tax authorities. Should any dispute arise with regard to the interpretation and application of tax or in relation to any tax returns, the Group is committed to addressing these issues in a courteous and transparent manner with the aim of seeking a timely resolution.
APPENDIX 1:
This tax strategy applies to the following entities for the 30 April 2024 accounting period (unless otherwise stated below):Hemingways Group Holdings Limited
Hemingways Marketing Services Limited
Voucher Express Limited
Hemingways Limited
Online Direct Services Limited
Bliss Systems Limited
Hemingways Marketing Services Pty (Australian entity treated as UK-tax resident)