UK Tax Strategy

Scope

This is the tax strategy applicable to Dalton Topco Limited and all of its subsidiaries (together the Dalton Topco Limited Group). It is published in accordance with para 19 (2), Schedule 19, Finance Act 2016 relating to the financial year ended 30 June 2024 and applies from the date of publication until it is superseded.

The Dalton Topco Limited Group (‘the Group’) is a leading manufacturer and supplier of dog, cat and small animal pet nutrition products operating across the dry, wet, and complimentary feeding segments of the market.

Aim

The Group considers tax compliance and disclosure of the utmost importance and upholds high standards of governance. The Dalton Topco Limited Group is committed to full compliance with all statutory obligations and full disclosure to relevant tax authorities.

The documentation of a UK Tax Strategy provides direction and control over the UK tax activity of the Group.

Governance in relation to UK taxation

The Board of Directors of Dalton Topco Limited (‘the Board’) has ultimate responsibility for ensuring that the Group’s UK tax affairs are conducted in accordance with this UK Tax Strategy.

The Board delegates responsibility to the Group’s Finance & Corporate Development Director.

Day-to-day responsibility of the Group’s tax affairs is delegated to the Group Director of Finance, Governance & Control, whose reporting line is to the Group’s Finance & Corporate Development Director.

The Group Director of Finance, Governance & Control has responsibility for the Group Finance Team, which is staffed with Colleagues who have the necessary experience for the role they are undertaking and who work closely with Site teams, and other Departments in the wider business, in the execution of their responsibilities.

It is the responsibility of the Group Finance Team to ensure that documentation evidences any facts obtained and conclusions reached during the course of their work, and where necessary that they take additional advice from appropriately qualified external tax advisors.

The Group observes all applicable UK laws, rules and regulations and ensures diligence and professional care and judgement is applied, and external advice is taken where appropriate in assessing and concluding on any uncertain tax positions.

The Group operates appropriate systems, controls, and processes to manage taxes in an effective and compliant manner. Review of these systems, controls and processes is undertaken to ensure that they remain fit for purpose and compliant.

Wherever possible, segregation of duties is maintained to mitigate the risk of errors, for example segregating the preparation of and review of tax returns.

Attitude towards tax planning & level of risk

The Group consistently considers its reputation, brands and corporate responsibilities when considering tax and tax initiatives.

All transactions are aligned with the commercial and economic activity of the Group’s operations.

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 that could materially impact its compliance with tax obligations.

The Group manages risks to ensure compliance with legal requirements to ensure the payment of the right amount of tax in line with statutory deadlines.

The Group does not undertake tax planning unrelated to commercial transactions.

As part of its commercial transactions, the Group seeks to utilize available tax incentives, reliefs, and exemptions in accordance with, and in the spirit of, tax legislation.

Where the tax impact of a transaction is complex or where tax legislation is unclear the Group seeks third party advice to ensure that the tax position adopted is expected to be acceptable to HMRC.

Relationship with HMRC

The Group seeks to have a constructive and transparent relationship with HMRC. The Group does not have a dedicated CCM. The Group seeks to communicate to HMRC any significant developments in its business, including future and retrospective tax risks and interpretation of the law in relation to all relevant taxes where appropriate.

The Group discloses all relevant facts and identifies any transactions or issues where it considers there is the potential for the tax treatment to be uncertain when submitting tax computations and returns to HMRC.

Should any inadvertent errors be identified in submissions made to HMRC the Group fully disclose these as soon as reasonably practicable after they are identified.

This UK Tax Strategy was approved by the Board of Directors of Dalton Topco Limited on 31st May 2024 for and on behalf of the Group.