Corporate Tax Strategy

Year ending 31st March 2024

Introduction

This document sets out the tax strategy for The Compleat Food Group of companies and their approach to conducting their UK tax affairs and dealing with UK tax risk as required by paragraph 16(2) of Schedule 19 of the Finance Act 2016. The Compleat Food Group is headed by Quantum Topco Limited and includes its subsidiaries and investments (“the Group”).

Scope

The strategy applies to Corporation Tax, Customs and Excise Duties, Employment Tax, Indirect Taxes, Stamp Duty Land Taxes and any other tax liabilities that the Group is liable pay and report to HM Revenue & Customs (HMRC) as set out in paragraph 15(1) of said Schedule.

Group’s tax strategy is to ensure that it complies with all tax laws wherever it does business and that it pays all taxes that it is legally required to pay when they fall due.

Approach to risk management and governance arrangements

The Board of Directors are ultimately responsible for determining the Group’s tax strategy and monitoring the application of the strategy.

The day-to-day tax affairs are managed by the Group Tax Manager. Executive responsibility for the delivery of tax management is with the Chief Financial Officer “CFO”) who also acts as the Senior Accounting Officer (“SAO”) for the Group and ensures that tax is properly considered during decision making.

The Group is committed to the following objectives when managing their tax affairs:

• Tax value: Efficiently manage the “tax burden” arising from its business activities, in compliance with all the relevant laws and obligations and with the principles and purposes of the tax system.
• Risks and reputation: Control and manage tax risks and protect the reputation of the Group through appropriate policies, procedures and controls.
• Tax compliance: Ensure that the Group acts with integrity and taxes due are correctly determined, respecting the timing and the requirements associated with them, to avoid disputes with the tax authorities.
• Promotion of a virtuous corporate culture: Promote awareness to the values – transparency, honesty and compliance with the relevant laws and regulation; at all levels within the organisation.
• Relations with the tax authorities: Establish relations with the tax authorities based on good faith and transparency with the aim of enhancing long-term relationships and being a trusted partner with the tax authorities.

Tax planning

Tax is an important consideration in strategic and operational decision-making processes. The objective of the Group’s tax planning activities aims to support the commercial needs of the business by ensuring that the Group’s tax affairs are performed in a tax efficient manner whilst remaining fully compliant with all relevant laws and regulation.

The Group will not engage in tax planning arrangements which are without commercial substance, or if the arrangements will potentially impact the Group’s reputation, brands, corporate and social responsibilities, or its future working relationship with the tax authorities.

The Group will not undertake tax practices or strategies that could be perceived as intended to erode the tax base or artificially transfer profits.

The Group will not undertake transactions, establish business relationships or implement corporate structures with the prevailing purpose of tax savings, in the absence of economic substance or other valid nonmarginal reasons.

The Group engages the services of professional advisors to advise in respect of the relevant taxes payable by the business where tax law is complex or new, is outside the experience of the tax team or where the treatment may be uncertain and the amount of tax involved is material.

Level of tax risk tolerated

Effective risk management is paramount for the Group and underpins its business strategy to strive to achieve “certainty” on the tax positions it adopts. The Group’s appetite for risk (including tax risk) is a carefully calibrated part of the business model aligned to the strategic and corporate objectives.

The Group takes the view, that whilst managing tax is a complex process, involving many different areas of the business, reducing tax risk to an acceptably low level is entirely feasible by ensuring that the overall governance procedures, including the internal control framework is robust and operating effectively.

The Group adopts a low tax risk approach and is committed to paying the right amount of tax at the right time.

Approach toward dealing with HMRC

The Group pursues a professional, courteous, transparent and open relationship with all relevant tax authorities, governments and related third parties, in particular acting in a cooperative and transparent manner.

The Group make appropriate disclosure of all transactions undertaken. We may seek certainty from relevant authorities on tax matters in advance of Relevant Transactions being undertaken.

If disputes arise, we seek to work in a collaborative manner to agree the facts and set out the technical position with the relevant tax authority as quickly and efficiently as possible.

Contribution to the UK economy

An assessment of a Group’s contribution towards the UK economy typically focuses on Corporation Tax, however this only reflects a small proportion of the overall fiscal contribution of a Group operating in the UK.

The Group makes significant other tax and duty payments as part of its normal operations. This includes Employer’s National Insurance Contributions, the Apprenticeship Levy, Business Rates, Customs Duty, Fuel Duty and Value Added Tax. The Group is a significant employer and operate across the UK, providing significant employment opportunities which generate income taxes and helps to support the communities in which the Group operates.

Board’s approval

This document is approved by the Board of Directors and annually reviewed and updated.

Publishing this document on the Group’s website is regarded as complying with the duty under Paragraph 16(2) of the Schedule.

Tom Riley
Chief Financial Officer