Tax Strategy

Introduction

This document sets out the UK tax strategy of The Criterion Group Companies for the financial year ending 31 March 2027. It is published on this website in order to comply with the duty under paragraph 16(2) of Schedule 19 to the Finance Act 2016, and it contains the information required by paragraph 17 of that Schedule.

This strategy applies to the UK group headed by Criterion Capital Limited and to all UK companies and UK permanent establishments within that group to which Schedule 19, Finance Act 2016 applies.

This strategy was approved by the Board of Directors on 31 March 2026 and is reviewed periodically, and at least annually, by the Board.

UK tax risk management and governance

We are committed to being a responsible and compliant taxpayer in all jurisdictions in which we operate, including the United Kingdom.

The Board of Directors has ultimate responsibility for oversight of the group’s UK tax strategy, risk management and governance arrangements. Day-to-day responsibility for managing the group’s tax affairs rests with the finance team, which reports to the Board and works with relevant internal stakeholders to identify, assess and manage UK tax risks arising from the group’s activities, transactions and operations.

The group maintains appropriate levels of internal competence in relation to corporate, employment, indirect and transactional taxes to ensure that tax returns are properly prepared and that UK taxes are accounted for and reported in accordance with applicable legal requirements. Appropriate systems, controls and review procedures are maintained to support compliance. Where matters are complex, material or uncertain, the group seeks support from appropriately qualified external tax advisers.

Attitude towards tax planning

The group does not enter into transactions or arrangements that are contrived, artificial or undertaken primarily to secure a tax advantage. The group does, however, consider the tax consequences of transactions undertaken in the ordinary course of its commercial and investment operations.

Where reliefs, exemptions or incentives are available, the group seeks to apply them in a manner consistent with the clear intent of the relevant legislation and published HMRC guidance. Where the tax treatment of a transaction is uncertain, complex or material, the group may seek advice from external tax advisers in order to support compliance with applicable law.

Level of risk in relation to UK taxation that the group is prepared to accept

The group’s objective is to comply fully with its UK tax obligations and to maintain a low level of tax risk. The group does not seek to adopt tax positions that are inconsistent with the law or that create material uncertainty without appropriate analysis and support.

Where uncertainty arises in relation to the correct UK tax treatment of a transaction or arrangement, the matter is considered by the finance team and escalated internally as appropriate. Significant or sensitive matters are brought to the attention of senior management and, where appropriate, the Board. External advice is obtained where necessary, and the group engages with HMRC where appropriate to obtain clarity on the correct treatment.

Dealings with HMRC

The group engages with HMRC openly, honestly and constructively in relation to its UK tax affairs. The group seeks to maintain a professional and transparent relationship with HMRC and to provide information in a timely manner.

The group shares information with HMRC regarding commercial developments or transactions where relevant, particularly where complex tax questions arise. Where there is uncertainty as to the appropriate treatment of a transaction, the group aims to engage positively and appropriately with HMRC so that matters are dealt with correctly, as far as possible, at all times.

This document is published on the internet and is available to the public free of charge.