GWR Tax Strategy

This tax strategy applies from the date of publication until superseded and pertains to the following UK companies (collectively, the “Group”):

  • GWRUK Acquisition Corp Limited (the "Company")
  • Guinness World Records Limited
  • GWR Branch Operations Limited
  • Ripley Entertainment Limited

The Group's ultimate parent is Jim Pattison Ltd. based in Vancouver, Canada. The Company is the head of the UK sub-group.

This document is being published pursuant to the requirements of paragraph 19 of Schedule 19 of the Finance Act 2016.

Overall Tax Strategy

The Group is fully committed to being a compliant taxpayer, where all tax returns are filed and all payments are made on time. The Group will also ensure that is using tax relief and credits provided by legislation, in a manner consistent with the spirit of the legislation, to improve after-tax cash flow which can be reinvested into the operations.

Managing Tax Risk

The tax risks covered by this strategy include direct and indirect taxes that arise in the UK. The strategy is owned by the Managing Director, Accounting from the ultimate parent company. Execution of the strategy as it relates to direct taxation is managed by the Senior Manager, Canadian and International Tax from the ultimate parent company. Execution of the strategy as it relates to indirect taxation is managed by the various finance teams for the UK operating companies within the Group.

Processes have been designed by those responsible for execution to ensure that compliance obligations are fulfilled. The management of tax risk includes balancing accuracy and efficiency within the processes that support business transactions and functions of varying size and complexity. Tax provisions and effective tax rates are reviewed regularly by senior management.

External advisors may be engaged if there is significant uncertainty around the legislation and its interpretation, which ensures that other viewpoints are considered before arriving at a conclusion. External advisors will also be consulted if expertise is required for a specialized area and the Group does not have the necessary skill set to handle an issue.

Attitude to Tax Planning

The operating companies develop and execute their business strategies based on the needs of their businesses. Tax structuring does not influence operating decisions as the operating companies are evaluated on pre-tax results. However, tax planning will be used to ensure that transactions are structured in an efficient and compliant manner. The Group does not undertake tax planning unrelated to such transactions.

The Group is guided by the core key values of honesty and integrity, and is focused on maintaining its brand and reputation. The Group will never engage in aggressive or artificial tax planning, and any structuring undertaken will be supported by commercial and economic substance. External advisors may be engaged to provide further input to ensure that material tax issues have not been missed or uncertain positions have been fully considered from all viewpoints.

Level of Tax Risk

There is no predetermined level of tax risk that has been set as acceptable. The Group’s tax appetite is influenced by the guiding principles and values set out above, and is consistent with the desire to achieve certainty with respect to the Group’s tax affairs. External stakeholders have no influence in determining the level of tax risk.

Working with HMRC

The Group seeks to work with HMRC in a co-operative and transparent manner. The Group endeavors to respond to HMRC requests in a timely manner, and will notify HMRC of any significant business transactions or changes when applicable. The Group will also ensure that any compliance errors discovered subsequent to the submission of filings are rectified.

In the event the Group and HMRC have different interpretations of the law which would result in disputes, the Group will seek to defend itself where it feels that it has a valid position that is supported by the law. Any such dispute will be handled in a professional, appropriate and co-operative manner.

PUBLISHED: December 13, 2017