Group Tax Strategy

Independence Matters Group Tax Strategy

1. Introduction
The purpose of this statement is to set out Independence Matters Group’s approach to tax, and it should be regarded as the Group’s tax strategy for the purposes of paragraph 16(2) Schedule 19 Finance Act 2016.
Management with responsibility for taxation will review and refresh this strategy annually and the Board of Directors will approve any amendments.
In this statement references to “Group” shall be references to Independence Matters CIC and all its subsidiary companies.

2. Group Tax Policy
Independence Matters Group is committed to conducting its tax affairs consistent with the following objectives:
i. to comply with all relevant laws, rules, regulations, and reporting and disclosure requirements; and
ii. to apply due professional diligence and care in the management of risks associated with tax matters, and in doing so ensure that appropriate governance and assurance procedures are implemented.

3. Principals of Ethical Business Conduct
Independence Matters Group expects all its employees and officers to act ethically in all dealings and business matters, including its tax affairs. Independence Matters Group requires that all staff should act honourably, with honesty and integrity, in compliance with all applicable laws and regulations, and in accordance with the highest moral/ethical standards of responsibility and accountability in all dealings with our customers, potential customers, business partners, suppliers, public officials, competitors and each other.

4. Tax Risk Management
Responsibility and accountability for the Group’s tax affairs is the responsibility of the Independence Matters Group Chief Finance Officer who reports directly to the Board of Directors. The Group’s Audit Committee also take an active role in understanding the tax treatment of material transactions.
Diligent professional care and judgement is employed to assess tax risks in order to arrive at reasoned conclusions on how the risks should be managed. Where there is uncertainty as to the application or interpretation of tax law, appropriate advice will be taken from third party professional advisers to support the decision-making process.
Risk management processes and systems include compliance and risk monitoring systems and internal reviews of tax compliance activity through Group.

5. Attitudes to tax planning
Independence Matters Group believes that it should pay the amounts of tax legally due. There will be circumstances where the amount may not be clearly defined, or where alternative approaches may result in differing tax outcomes. The Group will use its best judgement in determining the appropriate course of action, using available reliefs and incentives where possible. On occasions where the tax treatment of a transaction requires specialist tax knowledge the Group will seek external professional advice.

6. Independence Matters Group and its tax risks
Independence Matters Group has a low-risk appetite in terms of acceptable tax risk and seek to reduce tax risk wherever practical, which is achieved through:
i. the submission of all tax returns on a timely basis, including sufficient detail to enable tax authorities to form an accurate view of the affairs of the Group company and filing the tax return with an adequate supporting audit trail and sign-off process;
ii. paying the appropriate amount of tax at the right time;
iii. maintaining processes and controls that enable the company’s tax returns to be calculated correctly in all material respects;
iv. ensuring that key individuals who are involved in Independence Matters Group’s tax processes are adequately trained and supported to manage tax compliance issues on a knowledgeable and timely basis; and
v. ensuring that all tax filing positions are supported with appropriate documentary evidence.
Where there is a view taken by Independence Matters Group that may potentially differ to a position taken by tax authorities, Independence Matters Group aims to be transparent about the filing position it has taken.

7. Relationship with tax authorities
Independence Matters Group is committed to the principles of professionalism, openness and honesty in our discussions with tax authorities with an aim to establish a clear “no surprises” relationship.
The ultimate objective is to strive for early agreement on any disputed matters, and to achieve certainty wherever possible.

March 2025

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