The Euro Investments Overseas Group is required by paragraph 16 Schedule 19 Finance Act 2016 to publish a group tax strategy.

With regard to the requirements of paragraph 17 ibid, the Group’s approach to risk management is to minimise such risks to the greatest extent possible whether this be in relation to tax compliance work or transactions planning. As a commercial organisation, tax is considered to be a cost similar to others and accordingly, where possible, should be minimised within the constraints of the law. The Group only undertakes transactions it is prepared to fully disclose and does not undertake transactions that are without strong underlying commercial motivation.

The governance arrangements are ultimately the responsibility of the Senior Accounting Officer, Bill Procter. The actual work is delegated to Bruce Hunter, Tax Manager, who deals with corporation tax and the annual tax on enveloped dwellings, and Paul Hallam, the CFO, who manages compliance for employee taxes, VAT and stamp taxes.

The Group’s attitude to tax planning is to balance the requirements of the law and pay tax with its responsibility to its shareholders. The Group will not enter into any arrangements that would be notifiable to the tax authorities under mandatory disclosure regimes. The commercial needs of the Group are paramount and all tax planning will be considered in this context. All transactions must therefore have a business purpose or commercial rationale. The Group is conscious of the requirements of the Criminal Finances Act 2017 and intends to reflect these in its internal procedures.

The level of risk in relation to UK taxation that the Group is prepared to accept is regarded as being extremely low. Where the matter is subject to interpretation and is material, third party advice would be sought either from outside advisors or HMRC.

The Group’s approach to dealing with HMRC is to seek, wherever possible, to make tax filings, reporting and payments on a timeous basis thereby minimising any call on HMRC’s resources. The Group tries to resolve any enquiries quickly and with a minimum of discord.

The Group’s UK tax strategy was approved by the Board of Fairhold Services Limited on 22 December 2018. The Group’s UK tax strategy will be published by being included on the website of Estates & Management Limited, a subsidiary of Fairhold Services Limited.