Tax Strategy - Quintain Ltd

Tax Strategy

This document outlines the tax strategy of Quintain Limited and its UK incorporated subsidiary companies (“Quintain”) and sets out its approach to tax and the management of its relationship with HM Revenue & Customs (“HMRC”).

1. Summary

Quintain is committed to full compliance with its tax reporting obligations in the UK and in other jurisdictions in which it may decide to operate in. The group also provides support to our investors and stakeholders to help them comply with their tax reporting obligations.

It is Quintain’s policy not to engage in any transaction or structure that is contrary to the spirit and purpose of tax legislation, or that seeks to rely upon non-disclosure (in whole or in part) to HMRC. This policy also extends to any tax advantage which may be exploited by a third party.

The group maintains a low tolerance of tax risk. It seeks to operate on a low tax risk basis through having robust policies, procedures and controls to proactively identify and mitigate tax risks.

2. Tax risk management and governance

The group continually reviews the nature of its risk management procedures, but the core principle underlying all tax-related polices is to identify potential tax risks, assess the quantum and nature of those risks and then seek to minimise those risks.

This is achieved through constant engagement with business units, through a variety of formal and informal channels, which ensure that the tax team are fully aware of transactions and operating strategies at their inception. This knowledge is used to communicate with Executive Directors and the wider Finance team to ensure appropriate reporting and risk management procedures and controls are established and maintained.

Our tax team, led by Director of Tax and comprising experienced tax professionals, is responsible for implementing Quintain’s tax policy and ensuring compliance with this policy by the group. The tax team is responsible for ensuring that policies and procedures that support this approach are used consistently throughout the group. The tax team has the requisite skills to implement this approach, works closely with the business and other group functions and is supported by external advisors where necessary.

The Director of Tax reports directly to and meets regularly with the Chief Financial Officer to discuss tax issues and risks relevant to the business. Where appropriate, those risks are discussed with the Board during quarterly meetings or with Executive and other Operational Directors at weekly meetings.

3. Attitude to tax planning and managing risk in relation to taxation

Quintain actively seeks to avoid transactions or structuring of its affairs that are contrary to the commonly understood spirit and purpose of tax legislation, or that relies upon non-disclosure (in whole or in part) to HMRC. It applies this policy to internal and external transactions. When considering tax risk, the group takes into account our corporate and social responsibilities, any impacts on our relationships with tax authorities and on our reputation.

All material transactions and new business ventures are reviewed by the tax team before they receive approval.

The group seeks to avoid double taxation of profits and the non-deductibility of commercial expenditure, and structures its activities accordingly, except where legislation specifically denies such deductions.

The group prioritises certainty in tax affairs over achieving the lowest potential tax outcome. Where uncertainty arises, Quintain consults with advisors, and will disclose all relevant facts relating to a transaction to HMRC and, when available and appropriate, will present its proposed interpretation of the legislation for clearance by HMRC.

Quintain has a zero-tolerance policy on tax evasion including the activities which facilitate it. Consequently, Quintain is committed to ensuring that its businesses meet the compliance obligations of the UK corporate criminal offence of failure to prevent the facilitation of tax evasion.

4. Relationship with HMRC

Quintain is committed to maintaining an open, transparent and constructive relationship with HMRC, based on transparency and mutual respect.

The group aims to make all tax payments and submit all tax returns on time and with full open disclosure of all relevant matters.

The group maintains a regular dialogue with its Customer Compliance Manager at HMRC, both through scheduled meetings and on an ad-hoc basis.

Quintain seeks to ensure HMRC understand Quintain’s business model and commercial objectives.

Any enquiries raised by HMRC are dealt with promptly and openly.

Statement of compliance

This Tax Strategy document is consistent with Quintain’s overall strategy and operations.

This Tax Strategy was reviewed and approved by Quintain’s Board of Directors on 3 December 2025 and was published in December 2025 in accordance with Section 16(2) of Schedule 19 of the Finance Act 2016, in respect of the accounting period ended 31 December 2024.
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