This Tax Strategy Statement sets out the management of UK taxes by UK entities in the Walmart Inc. group (“the Group”).

This document is made available in accordance with Schedule 19 of Finance Act 2016 and is in relation to the financial year ended 31 December 2018. The Group considers the publication of this document as complying with the duty under paragraph 19(2)/22(2) and paragraph 25 of Schedule 19 of Finance Act 2016.

This statement is given in respect of the Group entities to which this legislation applies and where Walmart Inc. and its subsidiaries have a 51% or more holding in the relevant entity. The primary trading company in the UK is Asda Stores Limited.

The approach of the Group to risk management and governance arrangements in relation to UK taxation

The UK Chief Financial Officer (“CFO”) has responsibility for tax, and for communicating and advising on tax affairs and risks to the executive board (“the Board”).

Day to day tax matters are delegated to the Vice President of Corporate Finance (“VP-CF”), who in turn delegates to the Head of UK Tax who manages a professionally qualified tax team. When appropriate, external advice is sought from professional advisers, particularly for complex or uncertain matters, to support the Group’s decision making process.

The Head of UK Tax updates the VP-CF on a regular basis, and in quarterly formal meetings with the CFO, to ensure that there is an awareness of any risks associated with UK tax affairs.

The Group maintains a tax risk management framework, and a suite of documented tax process controls, to provide assurance to the Board that tax risk is being managed, and to certify compliance with the Sarbanes-Oxley Act, and the UK’s Senior Accounting Officer rules.

Attitude towards tax planning, so far as it affects UK taxation

All tax planning is driven by a business or commercial purpose. The Group is committed to acting with integrity and transparency on all tax matters and complying fully with UK tax law, which may involve claiming tax allowances, incentives, or exemptions, to which it is entitled under applicable laws and regulations.

Level of risk in relation to UK taxation that the Group is prepared to accept

Asda assesses risk on a case by case basis in line with the tax risk management framework. The Group’s objective is to comply with legal requirements in a manner which ensures the right amount of tax is paid at the right time, underpinned by an open and co-operative relationship with HMRC.

Approach towards the Group’s dealing with HMRC

The Group’s approach is to comply fully with UK tax law, making sure that all HMRC filings are submitted on a timely basis, with full disclosure, and that any areas of uncertainty are discussed with HMRC on a timely basis. The Head of UK Tax and his team have regular communication with the HMRC Customer Compliance Manager and specialist HMRC teams to promote a professional, collaborative working relationship which is based on principles of transparency and trust.


21st December 2018