Introduction & Overview
Group Business Strategy and Tax Objectives
This tax strategy sets out the Group’s approach to managing its tax affairs and the risks associated with them. The Group is committed to corporate and social responsibility while serving the interests of its customers, employees, suppliers, and stakeholders. The Group is, therefore, committed to complying with applicable tax laws in all countries in which it operates.
Tax matters are often a significant area of focus in a corporate transaction, and therefore a key objective of our strategy is to ensure that tax affairs of the Group are in good order and uncertainties are minimised.
Risk Management and Risk Appetite
The Group’s established ethical framework is such that deliberately failing to comply with tax law is unacceptable.
The Group’s appetite towards tax risk is governed primarily by the aim of retaining our low-risk rating from HMRC and a comparable standing with other Revenue Authorities. We have a low tolerance to tax risk, and we do not undertake transactions led by a tax planning purpose, but we do consider the tax consequences of our business transactions. This is because the Group has a responsibility to its shareholders to be financially efficient and deliver a sustainable tax rate in the context of the commercial needs of the Group and within all applicable laws.
When evaluating tax implications associated with commercial transactions, consideration will be given to the level of risk, the ease of implementation and consideration of any tax reliefs or opportunities available to us that are clearly within the applicable legislation and related Revenue Authority guidance, and to ensure that any eventual course pursued remains within the spirit of the legislation and guidance.
Tax Control Environment
The Group maintains internal competence in corporate and transactional taxes to ensure company corporate tax returns are properly prepared and indirect and payroll taxes are properly accounted for and reported, whilst tax advice is obtained from external tax advisors as appropriate.
Some reliance is placed on external advisors for advice relating to tax in the context of commercial transactions, technical updates and interpretations of tax legislation. Compliance is the responsibility of the business but will be monitored where appropriate by local external tax advisors.
The UK and International Finance teams are responsible for the maintenance of an appropriate tax control framework and a register of tax risks is maintained and updated to the internal risk management system. This is overseen and reviewed by the Risk and Compliance function and on a 6-monthly basis by the Board.
Governance
Strategy Oversight and Sponsorship
The Board is responsible for sponsoring and overseeing the overall Group Tax Strategy. Appropriate accounting and financial oversight is exercised through the Audit Committee with the Group CFO having oversight responsibility for the Group Board.
Management Reporting of Tax Risk
The Group CFO reports annually to the Board. The Board is provided with a monthly financial report, prepared by the CFO which, where appropriate, provides an update on key issues relating to tax and compliance matters.
It is the responsibility of the UK and International Finance teams to ensure all tax issues are reported promptly to the Group CFO as soon as they become aware of them.
Relationship with Revenue Authorities
The Group maintains open relationships with Revenue Authorities in all countries in which it operates and has a transparent approach to dealing with the relevant Revenue Authorities.
In the UK, D&G operates a real-time working relationship with its dedicated customer relationship manager at HMRC with regards to tax. D&G will raise any matters with HMRC, particularly to avoid uncertainty, for example where it considers that HMRC may take a different view, or where D&G is seeking confirmation of a particular approach.
This tax strategy is published in accordance with paragraph 16(2), Schedule 19 Finance Act 2016 and is in respect of the years ended 31 March 2022 and 31 March 2023.