Group Tax Strategy

Gregory Trading Holdings Limited

Tax Strategy for the 52 week period ended 28th September 2024

This document sets out the tax strategy of Gregory Trading Holdings Limited and its UK subsidiaries:

• Gregory Distribution (Holdings) Limited (Trading)

• Gregory Distribution Trading Ltd (Trading)

• Gregory Distribution Limited (Trading)

• Gregory Distribution (Contracts) Limited (Dormant)

• Gregory Distribution (Transport) Limited (Dormant)

• Kay Transport Holdings Limited (Dormant)

• Kay Transport Limited (Dormant)

• ARRC Holdings Limited (Holding company)

• ARR Craib Transport Limited (Trading)

• ARR Craib Transport (NEE) Limited (Trading)

• Pollock Holdings Limited (Holding company)

• Pollock (Scotrans) Limited (Trading)

• Pollock Express Limited (Trading)

(the “Group”). The publication of the Group’s tax strategy is in compliance with Schedule 19 of the Finance Act 2016.

This tax strategy applies to all UK taxes applicable to the Group and is approved by the Board of Directors of Gregory Trading Holdings Limited (the “Board”).

How the Group manages UK tax risks

The Group’s Board actively oversees the company’s risk and risk management practices. Tax risk is managed by:

• ensuring that there are experienced and qualified employees in the tax function;

• promoting a culture of good governance and compliance;

• maintaining robust procedures and controls to mitigate risk; and

• using appropriate external experts and advisors for review.

The Group’s business model and operating structure is simple and not subject to significant judgement in the application of tax legislation. The Group are committed to being a responsible and compliant taxpayer and always aim to pay the correct amount of tax in accordance with UK law.

The Group’s attitude to tax planning

The Group will only engage in responsible tax planning which reflects genuine commercial and economic activities. Where appropriate, it will take advantage of exemptions, tax incentives and reliefs in accordance with UK legislation. The Group does not enter into artificial arrangements designed to avoid taxation or engage in aggressive tax planning.

The Group will seek external tax advice in respect of areas where it does not have sufficient internal expertise.

The level of risk the business is prepared to accept for UK taxation

The level of risk the Group is prepared to accept for UK taxation is low and the Board are adverse to tax risks.

The complexity of tax legislation means that tax risks may arise due to uncertainties in interpretation and application. To minimise those risks, the Group seeks independent advice to ensure compliance.

The Group is privately owned and therefore there is no external shareholder pressure to maximise returns by taking tax risks.

How the Group works with HMRC

The Group maintains a professional, open and transparent relationship with HMRC in respect to matters relating to its tax affairs by:

• ensuring that all tax returns, reports and payments are accurately calculated and processed within a timely manner;

• working with HMRC to resolve any disputes or disagreements including providing any relevant information or correspondence requested; and

• being open and transparent in regards to decision making, governance and tax planning.

Publication date: 24 September 2024