Bellis Topco Limited (Asda) Group tax strategy statement

This Tax Strategy Statement sets out the management of UK taxes for Bellis Topco Limited and its subsidiaries (“the Group”, “Asda”), with the exception of Phantom Investments Limited and its subsidiaries [1] and Euro Garages (Jersey) Limited and subsidiaries [2]

It is made available in accordance with Paragraph 19(2) and Paragraph 22(2), Schedule 19 of Finance Act 2016 and is in relation to the financial year ending 31 December 2023. The primary trading company in the group is Asda Stores Limited, a wholly owned subsidiary of Asda Group Limited.

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

Bellis Topco Limited is ultimately responsible for the Group’s tax affairs. The Asda Group Limited Board (“the **Asda Board**”) is responsible for the management of Asda Group Limited and its subsidiaries, and reports to the board of Bellis Topco 2 Limited, the immediate subsidiary of Bellis Topco Limited (the “**Topco Board”**). The Asda Chief Financial Officer (“**CFO**”) is responsible for communicating and advising on tax affairs and risks to the Asda Board and the Topco Board.

Day to day tax matters are delegated to the Head of Tax and Treasury, 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 Tax and Treasury provides updates to the CFO on a regular basis including in quarterly formal meetings, 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, where relevant, for the UK’s Senior Accounting Officer rules.

The Group takes a zero-tolerance approach to the facilitation of tax evasion and is committed to upholding laws relevant to countering tax evasion, including the Criminal Finances Act 2017. The Group has a Prevention of tax evasion policy, periodic risk assessments are undertaken, and there is a working group tasked with the ongoing monitoring of procedures which reports to Asda’s Compliance, Ethics, Risk and Audit Committee.

**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, with full disclosure, and that any areas of uncertainty are discussed with HMRC on a timely basis. The Head of Tax and Treasury, and the tax 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.

[1] Phantom Investments Limited and its subsidiaries has a different management team, and its own governance arrangements. These companies will publish a separate tax strategy where required under Schedule 19 Finance Act 2016.

[2] On 31 October 2023, the share capital of Euro Garages (Jersey) Limited was acquired (“EG”) by the Asda. As EG and subsidiaries were under separate ownership up until 31 October 2023, a separate Tax Strategy Statement will be published for EG and subsidiaries for the year ended 31 December 2023. For future periods, these companies will be included in the Asda tax strategy statement, as management of tax matters will be under Asda tax governance.