12 Jersey Ltd – Tax Strategy

This document, approved by the board of 12 Jersey Ltd, sets out the company’s approach to conducting its tax affairs and dealing with tax risks. Publication of this tax strategy is regarded as complying with the duty under paragraph 16 (2) of schedule 19 of the Finance Act 2016 in respect of the financial year ending December 2025.

12 Jersey Ltd is committed to:

• Following all applicable laws and regulations relating to its tax activities.
• Maintaining an open and honest relationship with the tax authorities (including HMRC) based on collaboration and integrity.
• Applying diligence and care in our management of the processes and procedures by which all tax-related activities are undertaken, and ensuring that our tax governance is appropriate.

Governance in relation to UK taxation

Ultimate responsibility for 12 Jersey Ltd’s tax strategy and compliance rests with the board of 12 Jersey Ltd.

Day-to-day management of the company’s tax affairs is delegated to the Finance Director. The finance team is staffed with appropriately qualified individuals who ensure the board has oversight of the company’s affairs and an active role in decision-making.

Risk management

Managing 12 Jersey Ltd’s tax affairs is a complex process. As with any complex process, there may be risks of error or omission (tax risks) which may result in the incorrect application of tax rules or calculation of tax returns. 12 Jersey Ltd seeks to mitigate and reduce the level of tax risks arising from its operations as far as is reasonably practicable.

Identified tax risks are assessed on a case-by-case basis. Where there is significant uncertainty, external advice may be sought from reputable accounting and legal professionals to support the decision-making process.

When reviewing the tax risks associated with a specific decision or action, 12 Jersey Ltd ensures that the following are considered:

• The legal and fiduciary duties of directors and employees.
• All legal, regulatory, or compliance requirements.
• The requirements of any related internal policies or procedures.
• Any impact on stakeholders.

We believe this approach is in keeping with our desire to keep tax risk low.

Tax planning

12 Jersey Ltd has clearly defined lines of responsibility for its tax affairs, with decisions being taken at an appropriate level.

12 Jersey Ltd does not enter into artificial tax planning arrangements.

Our tax planning aims to support the commercial needs of the business by ensuring that the company’s affairs are carried out in the most tax-efficient manner while remaining compliant with all relevant laws. The finance function is involved in commercial decision-making processes to ensure a clear understanding of the tax consequences of any decisions made.

In complex cases where the tax position is unclear, external advice may be sought from reputable accounting and legal professionals.

How 12 Jersey Ltd works with HMRC

12 Jersey Ltd is committed to the principles of honesty, openness, and transparency in its approach to dealing with HMRC and commits to:

• Make fair, accurate, and timely disclosure in correspondence and returns, and respond promptly to queries and information requests.
• Seek to resolve issues with HMRC in a timely manner.
• Be open and transparent about decision-making, governance, and tax planning.
• Not enter into transactions that have the main purpose of gaining a tax advantage.
• Ensure all interactions with HMRC are conducted in an open, collaborative, and professional manner.