Tax Strategy

Vistry Group PLC Tax Strategy

June 2021

Scope

This strategy applies to Vistry Group PLC and to the group of companies headed by Vistry Group PLC (“the Group”) in accordance with paragraph 16 of Schedule 19 to the Finance Act 2016.

This strategy applies from the date of publication. References to ‘UK Taxation’ are to the taxes and duties set out in paragraph 15(1) of the Schedule which include Income Tax, Corporation Tax, PAYE, NIC, VAT, Insurance Premium Tax, and Stamp Duty Land Tax. All references relate to UK taxation as the Group has no subsidiaries incorporated or operating outside of the UK.

Aim

The Group is committed to full compliance with all statutory obligations and to managing its taxation in order to maintain both its corporate reputation and an open and transparent relationship with HMRC.

Governance in relation to UK taxation

The governance of the Group’s taxation is managed in the following distinct levels:

• Ultimate responsibility for the Group’s tax strategy and compliance rests with the PLC Board
• Executive responsibility of the Group’s tax is delegated by the Board to the Chief Financial Officer, who is also the Group’s Senior Accounting Officer
• Day to day management of tax matters rests with the Group Tax Director, overseen by the Chief Financial Officer

Risk Management

The Group operates a system of tax risk assessment and controls as a component of the overall internal control framework applicable to the Group’s financial reporting system. Through this, the Group seeks to reduce the level of tax risk arising from its operations as far as is reasonably practicable by ensuring that reasonable care is applied in relation to all processes which could materially affect its compliance with its tax obligations.

This framework is supported by advice from external professional advisors and proactive dialogue with HMRC where appropriate.

Attitude towards tax planning

The Group has a low level of appetite for tax risk. When entering into commercial transactions or making major business decisions, the Group will consider the tax implications in order to ensure that its obligations are fully understood and complied with and that any available incentives, reliefs and exemptions are taken into account. The Group does not undertake tax planning unrelated to its commercial transactions or allow tax planning to drive business decisions.

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

The level of risk which the Group accepts in relation to UK taxation is consistent with its overall objective of achieving certainty in its tax affairs. The Group seeks to comply fully with its regulatory and other obligations and to act in a way which upholds its corporate reputation. In relation to any specific issue or transaction, the Board is ultimately responsible for identifying the risks, including tax risks, which need to be addressed and for determining what actions should be taken to manage those risks, having regard to the materiality of the amounts and obligations in question.

Relationship with HMRC

The Group has an open and transparent relationship with HMRC and will proactively engage with its officers where appropriate in order to ensure HMRC is kept aware of significant transactions or to discuss any tax issues arising at an early stage. Any inadvertent errors in submissions made to HMRC are fully disclosed as soon as reasonably practicable after they are identified.