THE TRAVEL CORPORATION GROUP’S UK TAX STRATEGY

Scope
This strategy applies to all UK subsidiaries of The Travel Corporation Limited in accordance with paragraph 19 of Schedule 19 to the Finance Act 2016 (‘the Schedule’). In this strategy, references to ‘TTC’, or ‘the Group’ are to all these UK entities. The strategy has been published by Evan Evans Tours Limited on behalf of the group in accordance with paragraph 19(4) of the Schedule.

This strategy applies from the date of publication until it is superseded. References to ‘UK Taxation’ are to the taxes and duties set out in paragraph 15(1) of the Schedule which include Income Tax, Corporation Tax, PAYE, NIC, VAT, Insurance Premium Tax, and Stamp Duty Land Tax. References to ‘tax’, ‘taxes’ or ‘taxation’ are to UK taxation and to all corresponding worldwide taxes and similar duties in respect of which the Group has legal responsibilities.

Aim
The worldwide group is a leading provider of travel and tourism services consisting of over 25 different travel brands worldwide, taking over 2 million customers annually to over 70 countries.
The Group is a fourth generation, family owned business and prides itself on providing a quality service without compromising on its ethics or values, and is committed to helping the wider community and the environment.

TTC’s approach to tax risk management is aligned closely with the culture and the values at the heart of the organisation. The Group is committed to full compliance with all statutory obligations and full disclosure to relevant tax authorities. The Group’s tax affairs are managed in a way which takes into account the Group’s wider corporate reputation in line with TTC’s overall high standards of governance.

Governance in relation to UK taxation
Ultimate responsibility for the Group’s tax strategy and compliance rests with the Board of Directors of The Travel Corporation Limited
The Group’s Financial Controller has executive responsibility for TTC’s tax matters.
Day-to-day management of TTC’s tax affairs are delegated to the UK based finance team which is made up of suitably qualified individuals.
The Board ensures that TTC’s tax strategy is one of the factors considered in all investments and significant business decisions taken.

Risk Management
TTC operates a system of tax controls as a component of the overall internal control framework applicable to the Group’s financial reporting system.
There is a group-wide Finance and Risk committee that meets quarterly and assesses and monitors tax and other business risks.
TTC seeks to reduce the level of tax risk arising from its operations as far as is reasonably practicable by ensuring that reasonable care is applied in relation to all processes which could materially affect its compliance with its tax obligations.
Processes relating to different taxes are allocated to appropriate process owners across the Group, who are responsible for implementing controls and processes to manage their areas of tax risk.
The Group takes specific advice on identified areas of tax risk as required to order to minimise significant tax risks.

Attitude towards tax planning and level of risk
TTC manages risks to ensure compliance with legal requirements in a manner which ensures payment of the correct amount of tax.

When entering into commercial transactions, the group seeks to take advantage of available tax incentives, reliefs and exemptions in line with, and in the spirit of, tax legislation. TTC does not undertake tax planning unrelated to such commercial transactions.

The level of risk which TTC accepts in relation to UK taxation is consistent with its overall objective of achieving certainty in the Group’s tax affairs. At all times TTC seeks to comply fully with its regulatory and other obligations and to act in a way which upholds its reputation as a responsible corporate citizen. In relation to any specific issue or transaction, the Board is ultimately responsible for identifying the risks, including tax risks, which need to be addressed and for determining what actions should be taken to manage those risks, having regard to the materiality of the amounts and obligations in question.

Relationship with HMRC
TTC does not have a formal, dedicated point of contact at HMRC therefore the majority of its communication with HMRC relates to obligatory filing requirements. Above and beyond this the Group seeks to be cooperative with HMRC as far as possible and seeks to develop relationships with HMRC wherever possible.

To the extent that there may be any inadvertent errors in submissions made to HMRC, they will be fully disclosed as soon as reasonably practicable after they are identified.