Published: 12 December 2018
This document sets out the tax strategy for the UK entities of the Vacation Rental Group (listed in the Appendix) in conducting their tax affairs and dealing with tax risk. In making this information available the UK Group is fulfilling its responsibilities under Schedule 19 of the Finance Act 2016.
The tax strategy was approved by the Operating Council of the Group in December 2018 and applies from the date of publication until it is superseded.
Vacation Rental Group’s portfolio of brands has a significant presence in many major hospitality markets in Europe and is uniquely positioned to provide travellers access to a large assortment of travel accommodations and destinations. Our portfolio of brands include: Landal GreenParks, Novasol, Hoseasons, cottages.com, and James Villa Holidays.
Our European business activities incur a variety of taxes, including corporate income taxes, business rates, local taxes and, in the UK, employer’s national insurance. In addition, we collect and pay employment taxes, withholding taxes, and indirect taxes such as VAT.
The Group, understands that collecting and paying UK tax is an important contribution to the economy and society in the United Kingdom, and the Vacation Rental Group is committed to complying with UK taxation laws. We aim to pay the right amount of tax at the right time, and are committed to having an open and constructive relationship with HM Revenue and Customs (HRMC).
The Group’s UK tax planning aims to support the commercial needs of the business by ensuring that the Group’s affairs are carried out in the most tax efficient manner whilst remaining compliant with all relevant laws. The Group ensures there is a clear understanding of the tax consequences of any decisions made, taking into account the potential impact to its reputation and broader goals.
The Group’s Tax Director is therefore involved in the support of the commercial decision making processes, and provides appropriate input into business proposals of the Group to ensure a clear understanding of the tax consequences of any decision made. Where the Group does not feel it has the necessary expertise internally to assess the tax consequences conclusively, external advice will be sought to support the decision making process.
We do not engage in artificial or aggressive UK tax planning arrangements, with the sole purpose of obtaining a tax advantage. The Group adheres to relevant UK tax laws and seeks to minimise the risk of disputes or uncertainty with tax authorities. The Group conducts transactions between Group companies on an arm’s-length basis and in accordance with OECD principles.
Tax incentives and exemptions are sometimes implemented by governments and fiscal authorities to support investment, employment and economic development. We will apply these tax incentives and exemptions in the UK, in support of the Group’s commercial needs, if available and in the manner intended.
The Group seeks to build and sustain relationships with tax authorities that are constructive and based on mutual respect. We engage with HMRC with honesty, integrity, respect, fairness, and in a spirit of co-operative compliance. The Group is prepared to litigate where it disagrees with a ruling or decision, but will always seek to work collaboratively with HMRC to resolve disputes and come to an agreement and achieve certainty.
The Group proactively seeks to identify, evaluate, manage and monitor tax risk to ensure that they remain in line with the group’s risk appetite. Where required, external advice is obtained.
When reviewing the UK tax risks associated with a specific decision or action, the Group ensures that the following are considered:
The Group does not set formal quantitative risk limits in relation to the UK tax risk that it assumes. Instead, the UK tax risk profile of the Group is kept under continuous review. That profile is projected based on known or expected risks and settlements to allow an informed assessment of UK tax risk, management of that risk and any actions that might need to be taken. That review process may result in decisions in relation to the type and level of UK tax planning that is to be undertaken, but as noted above, is not governed by formal limits. This profile is actively managed and its status is monitored.
The Group does not engage in or facilitate any form of tax evasion.
The Operating Council of the Group is responsible for approving the tax strategy, and the Group Audit Committee monitors the Group’s tax affairs and risks through periodic review, and receive tax updates on a regular basis. Where tax decisions carry a material risk or relate to significant commercial transactions, these matters are presented to the Senior Leadership Team, who take into account the acceptable level of risk to the business but also consistency with the Group’s tax objectives.
The Group’s Chief Financial Officer is responsible for establishing, and sustaining appropriate policies, processes and systems, and for ensuring that the finance teams have the required skills and support to implement that Tax Strategy. The Group’s Tax Director supported by external advisors and expertise from the ultimate controlling party, is responsible for ensuring the day to day operation of the tax risk policies. The day-to-day compliance with all tax requirements is with the Finance teams headed by a CFO, Finance Director and Financial Controller in each territory as applicable.