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UK Tax Strategy

Tax Strategy Document

Introduction to Group structure

This strategy applies to Wolverhampton Wanderers Football Club (1986) Limited (“WWFC”) and to the group of companies (including all subsidiaries) headed by W.W. (1990) Limited (“the Group”) in accordance with the requirements of Schedule 19 to the Finance Act 2016. In this strategy, references to ‘WWFC’, ‘the Club’ or ‘the Group’ are to all such entities. The strategy is being published in accordance with paragraph 16(4) of the Schedule. This tax strategy was published on 29/05/20, and the Group and all subsidiaries regard publication as complying with its duty under paragraph 16 (2) Schedule 19 of the Finance Act 2016 in its Year Ended 31 May 2020. The tax strategy statement is reviewed annually and updated as necessary.

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

WWFC 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 Club’s wider corporate reputation in line with WWFC’s overall high standards of governance. WWFC acts as a responsible global corporate citizen.

Governance in relation to UK taxation

Ultimate responsibility for WWFC’s tax strategy and compliance rests with the Board of WWFC. The Board ensures that WWFC’s tax strategy is one of the factors considered in all investments and significant business decisions taken.

The Head of Finance has executive responsibility for tax matters and is also the Senior Accounting Officer (‘SAO’). Day-to-day management of WWFC’s tax affairs is delegated to the Finance Manager. The Finance Manager reports to the Head of Finance on WWFC’s tax affairs and risks throughout the year. The WWFC Finance and HR team is staffed with appropriately qualified individuals.

The Risk Committee’s requirement to monitor the integrity of the Club’s financial reporting system, internal controls and risk management framework, expressly includes those elements relating to taxation.

The SAO is responsible for ensuring the Club establishes and maintains appropriate accounting and tax compliance arrangements.

Risk Management

WWFC operates a system of tax risk assessment and controls as a component of the overall internal control framework applicable to the group’s financial reporting system. WWFC 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, who carry out a review of activities and processes to identify key risks and mitigating controls in place.  These key risks are monitored for business and legislative changes which may impact them and changes to processes or controls are made when required.

Appropriate training is carried out for staff outside the Tax team who manage or process matters which have tax implications. Advice is sought from external advisers where appropriate.

Attitude towards tax planning and level of risk

WWFC manages risks to ensure compliance with legal requirements in a manner which ensures payment of the right amount of tax.

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

The level of risk which WWFC accepts in relation to UK taxation is consistent with its overall objective of achieving certainty in the group’s tax affairs. At all times WWFC seeks to comply fully with its regulatory and other obligations and to act in a way which upholds its reputation as a responsible global 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

WWFC seeks a transparent and constructive relationship with HMRC through regular meetings and communication in respect of developments in WWFC’s business, current, future and retrospective tax risks, and interpretation of the law in relation to all relevant taxes.

WWFC ensures that HMRC is kept aware of significant transactions and changes in the business and seeks to discuss any tax issues arising at an early stage. When submitting tax computations and returns to HMRC, WWFC discloses all relevant facts and identifies any transactions or issues where it considers that there is potential for the tax treatment to be uncertain.