The Middleby Corporation and its UK subsidiary undertakings (the “Group”) regard the publication of this tax strategy statement as satisfying the statutory obligation under Paragraph 16(2), Schedule 19, Finance Act 2016 for the current financial year.
Tax risk management and governance
It is Group policy to fully comply with all tax laws and regulations. The Group maintains robust systems and processes to ensure tax liabilities are reported timely and accurately. Responsibility for the Group’s tax affairs is clearly defined. The Group’s Senior Accounting Officer (“SAO”) is ultimately responsible for tax risk management and governance across all taxes. The UK Finance, Tax and Payroll departments have day-to-day responsibility for tax compliance with support from the Group Tax department. The SAO monitors and oversees compliance with support from Group Tax and Internal Audit. Where appropriate the Group seeks advice from external tax advisers.
Attitude towards tax planning
The Group recognises the need to manage tax costs and operate tax efficiently. The Group makes use of tax incentives and reliefs, where available, and engages in tax planning to reduce tax costs where alternatives exist within the law. However, the Group does not engage in tax planning that is contrived or artificial nor does the Group structure transactions to produce tax results that are inconsistent with underlying economic activities.
Acceptable level of tax risk
The Group seeks to minimise tax risk wherever possible. The Group maintains procedures to identify, evaluate and manage tax risks on a real-time basis. This includes monitoring and assessing the impact of changes in tax legislation. Where there is uncertainty or complexity, the Group seeks advice from external advisers and/or open dialogue with HMRC.
Approach towards dealings with HMRC
Tax compliance for the Group is overseen by the Large Business group within HMRC. The Group values HMRC’s approach to Large Business tax compliance as it provides greater clarity, consistency and certainty over the Group’s tax affairs. The Group maintains a transparent, collaborative and professional relationship with HMRC. The Group regularly engages with HMRC in open dialogue, providing updates on business developments, disclosing one-off transactions or to discuss more routine matters. The Group aims to resolve uncertainty on a real-time basis and, where possible, reach agreement in advance of tax filings. The Group seeks formal HMRC clearance where appropriate. The Group fully cooperates with tax enquires and aims to provide prompt and complete responses to HMRC.
Last updated: 6th December 2018.