Richmond Group Tax Strategy

We, Richmond Group Limited (and our subsidiaries, but for the avoidance of doubt, excluding Amigo Holdings PLC and its subsidiaries) (together “RGL” or the “Group”) set out our tax strategy in accordance with paragraph 16(2) of Schedule 19 of the Finance Act 2016.

1. Approach to Tax Risk Management and Governance
1.1. Responsibility for the group tax strategy and management of tax risk is with the Board of Directors of RGL. Day-to-day management is undertaken by the Finance Director, whilst operational tax matters are managed by the Financial Accountant.
1.2. RGL endeavours to be fully compliant with tax legislation in the UK and in the relevant jurisdictions in which it operates.
1.3. RGL acknowledges risks which affect RGL’s compliance, including but not limited to the submissions of late or inaccurate returns, the failure to submits claims and/or elections or where systems fail to report data correctly.
1.4. The Group manages the key risks by a framework which is continually being adapted to meet the needs of the business. Where RGL acknowledges a particular risk (whether it be a transactional or a reporting risk), RGL seeks to take the appropriate advice.

2. Approach to Group Tax Planning
2.1. RGL adopts a tax planning approach which both balances the interests of key stakeholders and shareholders, whilst remaining compliant in the relevant jurisdiction in which it operates. All tax planning has a business purpose and is not designed to avoid its taxation responsibilities.
2.2. Where there is uncertainty concerning a tax position, appropriate advice is obtained to ensure that RGL remains compliant with all relevant legislation.
2.3. The implementation of RGL’s tax plans are deemed to be straightforward, simple and in the spirit of the law.

3. Approach to the level of risk in relation to UK Taxation that the Group is prepared to accept
3.1. RGL has a low risk appetite in relation to tax. Where RGL is unclear on the interpretation of relevant tax laws, RGL obtains external advice and, where RGL still remains unclear on the tax position, RGL takes the position which is unequivocally allowable under applicable tax laws.
3.2. RGL continually develops and purchases suitable financial software to manage its reporting and to ensure the accuracy of data required to tax reporting and filings.

4. Relationship with HMRC
4.1. RGL engages and seeks to comply with all relevant tax authorities, including but without limitation to, HMRC.
4.2. RGL responds to queries from HMRC in a timely fashion. The Finance Director and Financial Accountant manage the RGL’s relationship with HMRC with the aim of minimising the risk of challenge, dispute or damage to RGL’s reputation.

This Tax Strategy has been approved by the Board of Directors of Richmond Group Limited (for and on behalf of the Group).

We consider that this statement fulfils the duty of Richmond Group Limited to publish a tax strategy pursuant to paragraph 16(2) of Schedule 19 of the Finance Act 2016 for the year ended 31 March 2022.