Tax Strategy

This document, approved by the Board, sets out the Group’s approach to managing its tax affairs and dealing with tax risks for the financial period ending 30 March 2019.

The tax strategy applies to Bonmarche Holdings plc and its subsidiaries, and covers all corporate income taxes, indirect taxes, and employment taxes.

This document covers the Group’s strategic approach to its tax affairs, and how the Group treats areas of tax uncertainty and tax risk.

Bonmarche Holdings plc is listed on the Official List of the London Stock Exchange. The Company and Group are committed to high levels of corporate governance, and the Board acknowledges the importance of the principles set out in the 2018 Corporate Governance Code (the Code) published by the Financial Reporting Council. In relation to tax strategy, it is committed to promoting and maintaining responsible ethical behaviour and fostering open and transparent relationships with stakeholders.

Tax Approach
The Board believes that good corporate governance principles should extend to the Group’s attitude towards its tax liabilities. Therefore the Group’s objective in relation to managing and controlling its tax affairs is to comply with relevant legislation, whilst minimising its tax liabilities. The Group will therefore use all appropriate exemptions, reliefs or other tax planning mechanisms, provided that, when judged on a reasonable basis, they would not be considered ‘aggressive’. The Group is proactive, open and transparent in its dealings with HM Revenue and Customs.

The Group manages the taxes it pays having regard to the interests of its shareholders and other stakeholders. Any tax strategies or treatments being considered which might carry a degree of reputational risk (for example, actions which might be considered ‘tax avoidance’) would be required to be referred to, and approved by the Audit Committee prior to implementation.

Risk identification and reporting
The Group maintains a central risk register that is regularly reviewed and updated by the senior management team. At each review, any relevant tax risks are considered and documented in the risk register. The risk register is reviewed by the Board and Audit Committee on a regular basis.

As at the date of this document, no relevant tax risks have been identified in the risk register.

Roles and responsibilities
The Finance Director has overall responsibility for the execution of the tax strategy. The Finance Director acts as Senior Accounting Officer (SAO) and as part of this role must submit an annual certificate to HMRC stating that the Group has appropriate tax accounting arrangements.

Day to day management of tax returns and payments are dealt with by the Finance team, Payroll team, and third party tax specialists where required. Members of the Finance and Payroll teams responsible for accounting for tax are encouraged to undertake relevant training.

The Group has published this Strategy to meet its statutory obligation under the provisions of Schedule 19 to the 2016 Finance Act.

Dated 14 February 2019