Reviewed and updated August 2024
Introduction
This document sets out the tax strategy for Edward Billington and Sons Limited and its subsidiaries – (The Group) as required by para 16 (2) of schedule 19 of the Finance Act 2016.
This document will be reviewed by the group and approved annually by the Board of Directors to ensure it remains up to date in line with the group’s policies and practices. This document is published within the financial year ending August 2024 and a copy is available on the group’s website.
Tax Strategy – Key Summary
- The group complies with all applicable tax legislation and regulations
- We will cooperate fully with the tax authorities and provide complete and accurate information
- Employees of the group are obliged to comply with this policy at all times
- Before making any major changes in our business, we will ensure that any tax implications are understood and reflected accurately in our accounting records
The Billington Group
The group manufactures, merchants and distributes food, animal feed and other agricultural products and trades agricultural commodities. The group has manufacturing sites in the UK and sells to customers in the UK with some limited export sales. The group has approximately 1,900 employees across its sites and businesses.
Scope
The group is committed to conducting its tax affairs to comply with UK Tax legislation and manage its tax policy in accordance with the board’s principles and shareholder expectations. For the purpose of this tax strategy, tax is defined as a compulsory financial charge or levy imposed (direct and indirect) and includes:
- Corporation tax
- VAT
- National Insurance
- PAYE
- Excise duty
- Customs duty
- Land and property taxes
Our Principles
In respect of tax legislation, the group will pay its taxes and comply with all applicable laws and regulations in the countries it operates in. Openness and honesty are at the core of the group’s relationship with tax authorities and tax affairs will be conducted on sound commercial business principles.
When entering into commercial transactions, the group will use incentives, reliefs and exemptions in line with, and in the spirit of, tax legislation. It will not use them for purposes which are knowingly contradictory to the intent of the legislation.
The group operates a zero-tolerance approach to tax evasion whether carried out by an employee, or a business partner acting for us, or on our behalf. The Board of Directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it. Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training.
The group is committed to applying diligence and care in our management of tax risk. The policy is to minimise risk wherever possible. We seek to identify, evaluate and manage tax risks to mitigate such risks and where there is significant uncertainty or complexity in relation to a risk, external advice is sought.
Key principles:
- Conduct open and honest relationships with tax authorities at all times
- Compliance with all applicable tax legislations, reporting and disclosure requirements
- Align the tax strategy with the group’s management strategy, including risk appetite and the group’s values
- Conduct business on sound commercial principles and account for costs in a tax compliant and efficient manner
- Implement and maintain robust governance processes and compliance monitoring to maintain confidence in the group’s ability to produce accurate and complete tax submissions and the payment of taxes in a timely manner
Governance
The Board of Directors approves the group’s tax strategy annually in accordance with its risk management framework which is continually being reviewed. The Group Risk and Audit Committee has oversight of the policy and is responsible for monitoring compliance.
Implementation of the policy framework is delegated by the Board of Directors to the Finance Director’s of each business within the group. Decisions which affect business operations are taken at the appropriate level prescribed by the group’s delegation of authority.
The Finance Director of each business is responsible for its tax operations which includes the detailed analysis and preparation of the tax records and management of tax risk which is overseen by the Group Financial Controller and Group Finance team.
Risk Management
Professional diligence and care is applied to our management of all risks associated with tax matters to evaluate those risks. Appropriate training is carried out for staff who manage or process matters which have tax implications. Where there is uncertainty as to the application or interpretation of tax law, appropriate advice is taken from third party advisers.
Processes and Controls
Processes and controls are in place to manage the risk of erroneous tax payments and accounting. Tax processes and controls are reviewed and updated on a regular basis by the Group Financial Controller with oversight from the Chief Financial Officer.
Reporting and Monitoring
The group applies a three step approach to ensure the tax compliance process is adhered to:
- Tax processes are to be executed by suitably experienced and trained employees – the Group Financial Controller and Chief Financial Officer ensure that tax processes are adequately completed with the support of external advisors so that tax payments are accurate and submitted in a timely manner
- Senior management review – tax reporting and submissions to HMRC are subject to review by the Finance Director’s of each business with the supervision of the Group Financial Controller. Any deficiencies in internal controls in respect of tax matters are reported to the Group Risk and Audit Committee.
- Internal Audit – The group’s process and control environment are independently reviewed by Internal Audit. The scope of Internal Audit is agreed on an annual basis by the Group Risk and Audit Committee.
The group is subject to an independent audit on an annual basis and the audit of tax accounting is included within this process.
Recommendations which arise following the completion of audits outlined above will be reviewed by the Group Financial Controller and Chief Financial Officer and will be acted upon within a timeframe that is line with the group’s risk management framework and availability of resource.
Approach Towards Dealing with HMRC
The group is committed to the principles of openness and transparency in dealing with HMRC. When appropriate, the group ensures that HMRC is kept aware of significant transactions and changes in its business and seeks to engage in early dialogue with HMRC on any tax issues that arise. When submitting tax computations and returns to HMRC, commits to make fair, accurate and timely disclosure, and respond to queries and information requests in a timely fashion.
