UK Tax Strategy

Sinclair Motor Group UK Tax Strategy

(Revised 1 September 2021)

INTRODUCTION

In accordance with paragraph 17(4), Schedule 19, Finance Act 2016, Sinclair Motor Holdings Limited and its subsidiaries (Sinclair Group) consider the publication of the information below as complying with the duty to publish the Group's tax strategy as required by paragraph 16(2), Schedule 19, Finance Act 2016.

This tax strategy applies to all companies within the Sinclair Group, a list of which are shown in Appendix 1. All companies are part of the Group headed by Sinclair Motor Holdings Limited and are all registered and based in the UK.

OVERALL TAX STRATEGY AND PAYING THE CORRECT AMOUNT OF TAX

As a responsible taxpayer, Sinclair Group is committed to establishing, maintaining and monitoring an appropriate tax strategy. The overall objective of Sinclair Group’s tax strategy is to pay the correct amount of tax at the right time and to maintain an open and robust relationship with HMRC.

ATTITUDE TO TAX PLANNING

Sinclair Motor Holdings is committed to paying all the taxes that we owe in accordance with the spirit of all tax laws that apply to our operations. We believe that paying our taxes in this way is the clearest indication we can give of our being responsible participants in society. We will fulfil our commitment to paying the appropriate taxes that we owe by seeking to pay the right amount of tax, in the right place and at the right time. We aim to do this by ensuring that we report our tax affairs in ways that reflect the economic reality of the transactions we undertake in the course of our trade.

We will not seek to use those options made available in tax law, or the allowances and reliefs that it provides, in ways that are contrary to the spirit of the law. Nor will we undertake specific transactions with the sole or main aim of securing tax advantages that would otherwise not be available to us based on the reality of the trade that we undertake. The company will never undertake transactions that would require notification to HM Revenue & Customs under the Disclosure of Tax Avoidance Schemes Regulations or participate in any arrangement to which it might be reasonable anticipated that the UK’s General Anti-Abuse Rule might apply.

We believe tax havens undermine the UK’s tax system. As a result, whilst we may trade with customers and suppliers genuinely located in places considered to be tax havens, we will not make use of those places to secure a tax advantage, and nor will we take advantage of the secrecy that many such jurisdictions provide for transactions recorded within them. Our accounts will be prepared in compliance with this policy and will seek to provide all the information that users, including HM Revenue & Customs, might need to properly appraise our tax position.

WORKING WITH HMRC

The Group seeks to maintain an open, honest and positive working relationship with HMRC and is committed to prompt disclosure and transparency in all tax matters with them. The Group strives to comply with its tax filing, reporting and payment obligations in a way that balances against the commercial requirements of the business but always within the allowed time scales.

Regular review meetings are held between the Group’s Senior Accounting Officer (SAO) and HMRC’s Customer Relationship Manager (CRM) and their teams to discuss open issues and to discuss events occurring within the business. To this end, HMRC is aware of any one-off transactions before the tax returns containing those transactions are submitted.

Any disagreements with HMRC would be in respect of differing interpretations of how the law should be applied. These issues would be professionally addressed to maintain the mutual respect in our dealings with each other. Sinclair Group has no on-going disputes with HMRC.

RISK MANAGEMENT

CONTROLLING AND MANAGING RISKS

Sinclair Group has well established and documented processes and controls which consider potential tax compliance risks and the controls in place to mitigate these risks. These processes form the basis on which the Senior Accounting Officer (SAO) certificate is signed on an annual basis.

Sinclair Group has adopted a bottom-up approach to identifying any significant risk in the business. Broadly this encompasses processes and controls at site and Group level. How items are accounted for, the review processes in place to establish accounting integrity, the potential risks that could arise and how those risks are mitigated, are all documented, reviewed from time to time and audited.

COMPLIANCE AND REPORTING

Established processes and controls are in place to ensure that tax returns are submitted on time and without subsequent correction. All entries in the tax returns are evidenced with supporting documentation. All tax payment calculations are documented and reviewed using well established review procedures.

Relationships between the SAO and the rest of the business ensure that calculations are based on the most up to date relevant information. The SAO is a member of the Board which enables tax to be involved in the decision making in all areas of the business.

External third-party software is licensed for use by our external tax advisors for use in preparing certain tax returns. As well as providing an additional layer of integrity for HMRC, it ensures that any changes to legislation that impact tax calculations are correctly reflected in the tax returns as appropriate.

Our Annual Report and Financial Statements are freely available at Companies House. The Registered Office is also the Trading address of Sinclair Motor Holdings Ltd. All of the subsidiary companies are included in the consolidated financial statements of Sinclair Motor Holdings Ltd. All subsidiary companies are wholly owned and are incorporated in Great Britain and registered in England and Wales.

KEY ROLES AND THEIR RESPONSIBILITY

The Management Accountants employed within Sinclair Group’s Finance function are the key to the establishment and adherence to the Tax Strategy. Sinclair Group has always placed significant focus on its accountants and testament to this is that many members of the Finance team rank within some of the longest serving employees in the group. All Finance staff are either professionally qualified in Accountancy or by experience. Their wealth of experience and knowledge within the business is key to the success of the Tax Strategy. The membership of Professional Accountancy bodies ensures that Finance employees are up to date with legislative changes which impact the tax affairs of the business.

Internal The SAO works within Finance to ensure that tax payments are built into cash flow forecasts and that tax calculations and returns are based on accurate financial information. The SAO also works with other in-house departments (payroll, property, operational) to ensure that information required is provided on a timely basis. As a Board member the SAO is regularly updated by any matters concerning tax.

External It is recognised that from time to time the Group does not have the requisite experience or knowledge in-house and in such circumstances professional advice is taken from reputable external advisors. For example, the Group uses external professional services for the preparation of Corporation tax returns.

Outside specialists have also been used where it was considered that in so doing, the integrity of the tax returns and calculations would be maximised. For example, the use of external experts to identify appropriate VAT treatment of Dealer contributions.

Appendix 1

Members of the Sinclair Motor Group:

Sinclair Motor Holdings Limited
Sinclair Garages (Newport) Limited
Sinclair Garages (Port Talbot) limited
Sinclair Garages Limited
Sinclair Garages (Bridgend) Limited
Sinclair Garages (Cardiff) Limited
Sinclair Garages (Swansea) Limited
Swansea TPS Limited