This tax strategy document sets out the approach of the Trailfinders group of companies (Group) in relation to our tax affairs.

This document is thus published by Trailfinders Group Ltd, the parent company, on behalf of all the relevant group companies, and is published following approval by the Board of Directors. This tax strategy document is compliant with the requirements of Schedule 19 of Finance Act 2016 and in particular paragraph 16(2) of that Schedule.

Experts with the highest levels of integrity in tailormaking itineraries worldwide, Trailfinders is a multi-award winning Group founded in 1970 by former SAS officer Sir Mike Gooley CBE. The company remains privately owned but has a staff of over 1,000 and 43 travel centres staffed by the most expert travel consultants in the industry.

The principle companies of the group are:

• Trailfinders Ltd (incorporated in England)
• Trailfinders Ireland Ltd (incorporated in Ireland)
• Trailfinders Pty Ltd (incorporated in Australia)
• W8 Catering Ltd (incorporated in England)

In accordance with the relevant legislation, this tax strategy must set out details in relation to UK taxation but not necessarily taxation relevant to non-UK jurisdictions. In accordance with paragraph 16(4) of the Schedule, this strategy has been published as a standalone document and is made freely available to external stakeholders via the Trailfinders' website.

Its application extends to all aspects of the Group's tax affairs, including general tax compliance and tax payments and applies from the date of publication until it is superseded.

The approach of the Group to risk management and governance arrangements

We aim to be fully compliant with all aspects of UK taxation and indeed similarly in all countries where we operate.

Whilst the overall responsibility for our tax affairs rests with the Board of Directors, the day to day operations are conducted through our Finance Director, who has responsibility to take decisions in relation to the group tax affairs and to approve filings to be made to HM Revenue & Customs (HMRC) and other relevant revenue authorities.

In order to ensure the correctness and completeness of tax compliance filings a system of controls and processes have been developed to minimise the risk of errors arising beyond a materially acceptable level. This system is subject to periodic review both internally and externally, by auditors and revenue authorities, and is updated as appropriate for changes in legislation which may have an impact on its operation.

Utilising this system the Group seeks to minimise the level of tax risk that can arise from commercial operations as far as reasonably possible by taking reasonable care in application of those controls and processes, having particular regard to those transactions which could have a material impact on its tax obligations.

The aim of such an approach is to seek to maintain a low risk rating as determined by HMRC's Business Risk Review process. This is supported by the Group seeking:

• To maintain tax accounting arrangements suitable to the Groups operations;
• To make correct payments of tax, including estimated payments on account, when falling due;
• To make any necessary disclosures to the relevant regulatory body;
• To make timely filings of relevant tax returns.

The Group utilises external advisors to prepare and submit annual Corporation Tax returns to HMRC.

The attitude of the Group towards tax planning

The Group seeks to adhere to principles of integrity in all commercial dealings. This therefore equally applies to aspects of taxation. The Group is aligned to the concept of 'paying the right amount of tax' and paying this on time.

The Group does not engage in any artificial tax planning arrangements whose sole purposes is to reduce the level of tax. In relation to all UK taxes (including PAYE, NIC, Corporation Tax, VAT, ATED, SDLT, IPT) the Group seeks to ensure compliance with relevant legislation, accounting for transactions in line with underlying commercial rationale.

Where there may be doubt about the tax treatment of a transaction the Group will seek external professional advice and will apply that advice as appropriate. In cases where genuine alternative tax treatments may exist for any commercial transaction the most tax efficient approach will be taken, subject to ensuring compliance with existing legislation and overall Group objectives.

Where the Group is eligible, and as approved by HMRC, advantage will be taken of available tax incentives, reliefs and exemptions as set out in legislation.

The level of tax risk that the Group is prepared to accept

The Group's commercial operations are subject to numerous risks such as currency movements, terrorism, disease, adverse weather conditions and other natural phenomena. In addition the Group has an Air Travel Organisers Licence granted by the Civil Aviation Authority and is thus both mindful of and compliant with the legislative burden placed on the travel industry in particular the EU Directive on Package Travel.

Accordingly any acceptable level of risk in relation to the Groups' tax affairs is constrained by the commercial and legislative risks that arise from day to day operations and the additional objective of maintaining its reputation of corporate responsibility aligned to its involvement in charitable activities.

The Group adopts a prudent approach when considering tax risk ensuring as appropriate this is minimised by adopting full disclosure and having an open dialogue with HMRC on any material areas of risk identified.

The approach of the Group towards its dealings with HMRC

The Group is part of HMRC's Large Business customer relationship model. This is based on HMRC principles of "mutual trust, transparency and resolving issues in real time", which the Group adheres to.

HMRC originally published a draft Framework for Cooperative Compliance for dealing with Large Business, and this was subsequently incorporated into their Tax Compliance manual on 9 May 2022. This addresses the relationship between large businesses and HMRC and promotes best practice in a business' governance over its UK tax affairs.

This Group's tax strategy is aligned with this published draft. In particular, the Group:

• Promotes collaborative professional working with HMRC, building an open, transparent and trusted relationship;
• Engages in open and early dialogue with HMRC to discuss tax planning, strategy, risks and significant transactions and fully discloses any significant uncertainty in relation to tax matters;
• Responds to queries, information and requests in a timely fashion;
• Seeks to resolve issues with HMRC in real time and before returns are filed if possible;
• Makes fair, accurate and timely disclosure to HMRC in relevant returns and documents;
• Where disagreements over tax arise, will work with HMRC to resolve issues by agreement (where possible) and reach reasonable agreement;
• Is open and transparent with regards to decision making, governance and tax planning, keeping HMRC informed of who has responsibility and how decisions are reached;
• Avoids structuring transactions in a way which will have tax results that are inconsistent with the underlying economic consequences unless there exists specific legislation designed to give that result;
• Interprets the relevant tax laws in a reasonable way, and ensure transactions are structured in a way that is consistent with a relationship of co-operative compliance with tax authorities;
• Applies an "Openness and Early dialogue" approach which sets out the specific tax risk identified and avoids opening unnecessarily wide-ranging enquiries;
• Discusses risks and transactions on a "real time" basis (i.e. pre-transaction or pre-return).

As a consequence of this the Group has regular interactions with HMRC. The Group further seeks, as far as possible, to quickly address any areas of doubt where these arise.

Where there remain areas of doubt the Group seeks to fully make appropriate disclosures on submissions to HMRC and in the event of any errors being identified these are immediately addressed, again being fully disclosed as necessary.

The Group is also within the Senior Accounting Officer legislation, as set out in Schedule 46 Finance Act 2009, requiring an annual declaration aligned to ensuring the group has appropriate tax accounting arrangements in place founded on accepted underlying tax governance and systems.

In the Financial Year ending 28th February 2023, the Group paid the following to UK Government agencies:

• Corporation Tax payable in the UK of £1.5m
• Employer National Insurance Contributions of £4.4m
• Council Tax and Business Rates of £1.9m
• ATOL fees of £0.2m
• Apprenticeship Levy of £0.2m
• Air Passenger Duty of £23.0m
• PAYE of £6.3m
• Employee National Insurance Contributions of £3.1m

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Updated by Lawrence Comber, 8th January 2024

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