This Tax Strategy is published in accordance with paragraph 19 of Schedule 19 of Finance Act 2016 for accounting period ended 30 September 2025 and applies to the following UK entities of the Stock Spirits Group (“SSG”), (together referred to as the ‘Stock Spirits UK Group’ or ‘the UK Group’):
Sub-group 1’s business is in the process on being wound up.
SSG is a leading producer of spirits in Europe and the UK group is concerned with the sale of spirits and the licensing of SSG’s brands.
References to ‘UK taxation’ are to the taxes and duties set out in paragraph 15(1) of Schedule 19 of Finance Act 2016.
I. Approach of the UK Group to risk management and governance arrangements in relation to UK taxation
The UK Group is committed to fulfilling its compliance and reporting responsibilities under UK tax legislation. It maintains internal policies and procedures to ensure consistent application of its tax governance standards across all entities. It seeks the ensure that appropriate internal processes and systems are maintained and adequately resourced to meet its statutory obligations on time and to support accurate and transparent reporting.
The UK Group seeks to manage UK tax risks through structured oversight and robust internal processes, with support from external UK tax advisors where appropriate. Tax risks are identified, assessed, and managed to ensure they remain within acceptable levels, including the tax implications of key business decisions such as reorganisations, restructurings and commercial initiatives. The UK Group aims to ensure that all material tax issues are discussed with external UK tax advisers. Tax processes and controls are subject to periodic review to reflect changes in legislation, business operations, and transactional activity. Where appropriate, controls are updated to ensure continued compliance and effective risk management.
The Board of Directors of the UK Group has ultimate responsibility for UK tax affairs, with oversight from the Board of Directors of SSG, while operational responsibility is delegated to senior finance and tax professionals (lead by Head of Tax of Stock Spirits Group).
II. Attitude of the UK Group towards tax planning
The UK Group acts in accordance with SSG’s Code of Business Conduct and Ethics and approaches tax planning ethically and pragmatically, based on business and economic considerations. Commercial rationale drives all structuring decisions. The Group does not engage in any artificial arrangements or aggressive tax schemes. It does not undertake actions or activities where one of the main purposes is to secure a tax advantage not intended by legislation. Where relevant, the Group seeks to ensure that it utilises available tax reliefs and incentives in a manner aligned with the intention of UK law. Where it is concluded that more than one legitimate option exists, the UK Group may choose the most tax-efficient path which is aligned with UK policy intent.
Where appropriate, the UK Group will seek external advice to ensure that complex transactions are structured in compliance with both the letter and spirit of UK legislation.
III. Level of risk in relation to UK taxation that the Group is prepared to accept
The Group is committed to acting responsibly in relation to its tax affairs. When evaluating tax risk, the UK Group assesses the significance of each matter alongside the resources required to manage it effectively and seeks to adopt a prudent approach in each case.
Where the UK Group identifies uncertainty in relation to tax, e.g. in relation to the application of transfer pricing rules which are inherently subjective, it routinely seeks external professional guidance to reduce such uncertainty, and if appropriate will also seek to discuss uncertain tax positions with HMRC in an open and transparent manner.
IV. Approach of the Group towards its dealings with HMRC
The UK Group aims to maintain an open, transparent and constructive relationship with HMRC. Where appropriate, the UK Group will seek clarification from HMRC where the interpretation of UK tax law is unclear.
Where any potential disputes arise, in the first instance, the UK Group will seek to resolve any differences through transparent discussions with HMRC and where agreement cannot be reached, would aim to resolve disputes constructively and co-operatively.
