Hawthorn Leisure Holdings Limited and Subsidiaries - Tax Strategy

Hawthorn Leisure Holdings Limited and Subsidiaries - Tax Strategy

Hawthorn Leisure Holdings Limited and subsidiaries - Tax Strategy

Hawthorn Leisure Holdings Limited is a limited company incorporated in England and Wales and tax resident in the UK. This strategy applies to Hawthorn Leisure Holdings Limited and its subsidiaries in accordance with paragraphs 19 and 25 of Schedule 19 to the Finance Act 2016. A full list of the entities to which it applies is set out below. In this strategy, references to ‘Hawthorn’ are to all these entities.

The strategy has been published in accordance with paragraph 16(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 This strategy applies from the date of publication until it is superseded.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, Machine Games Duty, Insurance Premium Tax, and Stamp Duty Land Tax. References to ‘tax’, ‘taxes’ or ‘taxation’ are to UK taxation in respect of which Hawthorn has legal responsibilities.

This strategy was approved by the Board on 20 December 2017.

Hawthorn’s approach to risk management and governance arrangements in relation to UK taxation

Ultimate responsibility for Hawthorn’s tax strategy and compliance is held by the Board of Directors. The Board review the tax strategy at least annually, and any changes to the tax strategy are approved by the Board. Where changes are made, the tax strategy will be republished, superseding previously published strategies.

Responsibility for the tax strategy is delegated by the Board to the CFO, through his appointment as Senior Accounting Officer. The directors, and CFO, are responsible for developing and maintaining the tax strategy and for managing the tax risk, including design and implementation of new controls or processes where tax risks are identified.

The CFO has responsibility for ensuring that Hawthorn complies with its statutory obligations, and with its tax strategy, as well as for ensuring appropriate processes and controls are in place to enable accurate and timely tax reporting. Day-to-day analysis and preparation of tax records, returns and computations are performed by key members of the Finance team, although the CFO is responsible for their approval prior to being published or submitted to HMRC as relevant.

Hawthorn’s attitude towards tax planning

Hawthorn is committed to full compliance with all statutory obligations, although Hawthorn takes advantage of allowances, reliefs and exemptions available under UK tax legislation, to enable Hawthorn to manage the level of tax paid.

Hawthorn also assesses the tax implications when considering strategic changes to the business, including commercial opportunities and material business transactions, such as debt and equity refinancing, acquisitions and disposals. Where there is expected to be a tax impact Hawthorn seeks advice from external tax advisors to ensure that all relevant tax implications are considered and appropriately accounted for, disclosed and reported.

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

Hawthorn aims to manage its tax risk to ensure compliance with legal requirements such that it is able to calculate and pay its tax liabilities in line with the statutory payment deadlines.

Hawthorn manages and monitors its exposure to tax risks through ensuring appropriate controls and procedures are in place in all areas of UK tax.

Hawthorn also ensures that those involved in the preparation of tax returns, reports or disclosures have sufficient experience and qualification to do so, and supports its employees in furthering their tax knowledge. Hawthorn stays abreast of upcoming / existing legislative requirements through their tax advisors, and will obtain further support where they impact Hawthorn if needed.

Where new tax risks or issues are identified within the Finance team or wider business, the open and honest communications within the business encourage any member of staff to report these direct to the CFO, or via their line manager. The CFO is responsible for implementing new controls or procedures as required to mitigate the risks, and for escalating any risks or issues to the Board if material.

Hawthorn’s approach towards its dealings with HMRC

Hawthorn remains open and honest in its communications with HMRC, through additional disclosures in submitted computations and returns, as well as in correspondence with HMRC.

Hawthorn liaises with HMRC to determine and agree where possible the correct treatment of key items, and its compliance requirements, wherever it is uncertain of the prevailing rules to apply. In the event of any material inadvertent errors arising, full disclosure, where required by law will be made to HMRC.

List of entities covered by this Tax Strategy

  • Hawthorn Leisure Holdings Limited
  • Hawthorn Leisure Limited
  • Hawthorn Leisure Acquisition Limited
  • Hawthorn Leisure Honey Limited
  • Hawthorn Leisure Management Limited
  • Hawthorn Leisure Finco Limited
  • Hawthorn Leisure Scotco Limited