Tax Strategy


This document sets out The Kay Group (UK Holdings) Ltd and its subsidiaries` approach to handling its tax affairs, for the period ended 31st October 2023.

It is designed to comply with the group`s requirements under Schedule 19 of the Finance Act 2016 and has been approved by the Board of The Kay Group (UK Holdings) Ltd.

Tax Strategy

The group`s objective is to comply with UK tax legislation and pay the correct amount of tax where necessary.

The approach of the group to risk management and governance arrangements in relation to UK taxation

The Board is responsible for ensuring compliance with UK tax law. It achieves this through the work carried out by internal teams and utilising external tax and legal teams as and when required.

It is responsible for ensuring that tax risk is managed appropriately and meets the overall attitude towards acceptable levels of risk. The overall aim is to manage and reduce any tax risk across all taxes to an acceptable level. Material transactions are therefore reviewed for tax risk by the Board, as well as tax and legal teams where necessary.

External qualified advisors that are competent with the required knowledge in each area of taxation are used to ensure compliance with local tax legislation and to mitigate any tax risk arising.

Inter-company transactions are commercially driven and not undertaken with the aim of mitigating tax.

The attitude of the group towards tax planning

Tax planning can be undertaken to utilise tax incentives or reliefs as set out in legislation. This will only be undertaken where the underlying transaction meets the commercial and governance objectives of the group. Any planning is aligned with the group`s values of complying with tax legislation and paying the correct amounts of tax when legally due.

The group does not enter into artificial transactions which lack economic substance in order to reduce tax. The group also does not use nil or low corporate income tax jurisdictions to artificially reduce tax liabilities.

Where legitimate and commercially driven tax planning is undertaken, external advice will likely be sought to ensure that the planning is carried out efficiently, but also that it is carried out in accordance with the intentions of parliament and the purpose of the applicable legislation.

An external tax team will likely be involved for significant transactions to assess the potential tax impact and to manage the related tax risks. The assessment of risk and compliance is undertaken across all taxes.

Managing risk in relation to UK taxation

The group has a risk-averse approach to managing tax risk and will only accept a low level of risk that does not have a material impact. The Board will review each material transaction on an appropriate basis to assess any risk and to ensure that it meets internal risk and control objectives set by the group.

Where there is uncertainty as to the application of the legislation, or where we believe we do not have the necessary expert knowledge, appropriate external advice will be sought to help assess the risk and provide support on reaching the correct tax position.

Professional care is taken when the group are deciding on the levels of tax risk to accept.

The approach of the group towards dealing with HMRC

The group`s aim is to have an open and constructive relationship with HMRC and it also aims to ensure all tax filings and tax payments are made to HMRC on a timely basis to meet statutory deadlines to reduce the risk of penalties. This is consistent across all taxes and related tax filing obligations.

Accurate and timely disclosures are made in the tax computations and returns to reflect transactions undertaken and any positions taken where the tax treatment is uncertain are appropriately identified.

If inadvertent errors occur in the tax submissions, full disclosure is made to HMRC as soon as is reasonably practical once the errors have been identified and any outstanding tax settled promptly.

In the event of a disagreement with HMRC, the group seeks to resolve all such disputes on a timely basis. The group will likely also engage external advisors to help resolve the dispute where appropriate.

List of entities covered by this Tax Strategy

  • The Kay Group (UK Holdings) Ltd
  • The Kay Group (UK) Ltd
  • Intack Self Drive Ltd