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31 December 2023

The purpose of this document is to outline the approach adopted by KTC (Edibles) Holdco and its subsidiaries in managing its tax obligations and activities across the business. The strategy is published pursuant to paragraph 16 of Schedule 19 of the UK Finance Act 2016 and was approved by the Directors at a Board meeting on the 21 November 2023 and applies from the date of the Board until it is superseded. It will, at the very least, be updated annually in accordance with UK legislation and published on our website.
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Since the last tax strategy, the Group has acquired Cardowan Creameries (based in the UK) and Trilby Trading Ltd (based in the Republic of Ireland) and these companies are covered by this tax strategy.
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The tax strategy covers four areas:How we manage UK tax risks.Our attitude to tax planning.The level of risk we are prepared to accept for UK taxation.How we work with HMRC.
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How we manage UK tax risk
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The CFO of the Group acts as the Senior Accounting Officer for each of the companies and has overall executive responsibility for all tax matters and day to day management of tax affairs.  Tax risks are monitored and where significant are discussed with the Board which has overall accountability for managing risk, which includes tax risks.
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Given we operate only in the United Kingdom and Ireland, predominantly in VAT exempt food items, the tax policy and the relevant laws and regulations that affect tax affairs are simple and easy to monitor. We have been assessed by HMRC as a low-risk entity in April 2021 for the next 3 years.  
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When risks are identified, they are discussed with our external advisors and appropriate action taken.  
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The Group’s attitude to tax planning
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We make tax planning decisions based on several factors including financial, legislative and reputational risk factors. Our aim is to ensure all transactions are structured in a compliant and tax efficient manner and we have zero tolerance to tax evasion. We engage the support of tax advisors in all significant tax planning decisions.
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The level of risk the Group is prepared to accept for UK taxation
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The Group aims to be a responsible taxpayer and adopts a conservative approach to tax matters.
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How the Group works with HMRC
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The Group has a Customer Compliance Manager who is kept informed on tax matters. We are committed to acting in an open, honest and transparent manner in our dealings both with him and all tax authorities.

In respect of tax compliance:
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• We aim to pay all tax we are legally obliged to pay, as and when it becomes payable.
• We aim to comply with all relevant tax laws in all jurisdictions in which we have a presence.
• We aim to disclose to the tax authorities any inadvertent errors or emissions in tax returns or underpayments of tax in a timely manner.

Approved by the Board on 21 November 2023