Calbee Group (UK) Limited Tax Strategy Statement for the year ending 31 December 2022

We regard our tax strategy to be compliant with Schedule 19 Finance Act 2016 in terms of content and meeting our responsibility to publish our strategy.

As a UK company, which is part of a larger international group listed on the Japanese Stock Exchange, we recognise the importance of meeting our responsibilities for paying tax and being open and compliant in these responsibilities as well as ensuring we operate under good corporate governance.

We are committed to a tax strategy that involves paying the correct amount of tax at the right time and maintaining an open dialogue with HMRC. We do not undertake what may be regarded as aggressive tax planning.

The key performance measures of the group, which apply to our company, are EBIT, cash flow (excluding tax payments) and return on capital employed based on the EBIT figure. The use of these measures by the group as a whole offers no incentive for member companies to compete on tax rates or use aggressive tax planning schemes.

Our overall tax strategy, as it relates to UK tax, is to:

• Comply with all legislative requirements in relation to tax
• Submit all tax returns and make all tax payments by the due dates
• Pay the correct amount of tax based on the profits earned by the business and not to seek ways to artificially reduce those profits
• Continue to maintain an open, honest and proactive relationship with HMRC
• Have in place risk management and control procedures in relation to tax.

Risk management and governance arrangements

We recognise that managing tax compliance is becoming increasingly complex and to enable us to meet our obligations, we have put in place the following arrangements:

• The use of external advisers for managing some of the group’s tax compliance procedures.
• The use of advisers with the relevant expertise where specialist advice is required.
• The Calbee Group (UK) Limited Finance Director is responsible for overseeing the tax affairs of the UK group and reporting back to the Board.

Tax planning

Tax is not a key business measure nor is it a driver for undertaking transactions. Consequently, we do not engage in aggressive tax planning.

Investment decisions are made by considering the payback before tax. Once an investment decision has been made, if appropriate, the company will then take advice on the tax effect of the transaction with the aim of getting our tax calculation correct and being able to justify any claims that are made.

Attitude towards risk

The UK Company and the international group wish to maintain a low risk profile in the countries in which they operate. We have no desire to undertake any transactions which would put this position in jeopardy.

The Board of our company sees compliance with tax legislation and openness with HMRC as key to managing our tax risk and we aim to act within the intentions and spirit of tax legislation.

We have relationships with professional advisers that allow us to seek expert advice on specialist areas of tax or where we undertake any transactions which are outside of the normal course of business. Our approach is to ensure we are compliant, have good internal procedures in place, and understand our responsibilities with regards to tax and to pay the correct amount.

Relationship with HM Revenue & Customs (HMRC)

Calbee Group (UK) Limited aims to have an open and professional relationship with HMRC. We use our professional tax advisors as agents in relation to corporation tax, who deal with HMRC on the Company’s behalf. The company does not have a Customer Relationship Manager at HMRC and is not subject to the Business Risk Review process or risk rating. If the company were subject to the Business Risk Review process, it would seek to achieve a ‘low risk’ rating. The company aims to provide correct and timely disclosure in tax correspondence and returns. The intention is to respond to HMRC queries in a timely fashion.