Tax Strategy

Gannett UK Tax Strategy

In accordance with Finance Act 2016 Schedule 19 Part 2 the Gannett International Holdlings LLP group’s tax strategy in relation to UK tax for the years to 31 December 2022 and 31 December 2023 is set out below.

1.      Introduction

This document covers all UK companies and LLPs within the Gannett UK group (the “Group”), all of which operate within the publishing and printing industry in the UK.  The Group is wholly owned by Gannett Co., Inc, a company listed on the New York Stock Exchange.

The tax strategy below details the Group’s attitude towards tax risk and management, covering all areas of UK tax.

2.      Approach to tax planning and risk

The Group’s approach to tax planning in respect of UK taxation is to aim to comply with relevant tax legislation rather than to proactively pursue aggressive tax planning.

The Group operates as a community publisher in the United Kingdom and to be consistent with its goal of promoting local accountability it aims to meet its statutory tax compliance obligations efficiently and effectively.  The nature of the Group’s activities means that its day to day operations do not generate many complex tax issues.  As such the Group believes it is exposed to minimal tax risks, which have been identified as follows: 

·       Tax compliance and reporting risks – due to the complexity and bureaucratic nature of the tax legislation and system this risk is difficult to eliminate entirely. 

·       Transactional risks – which may arise where unusual transactions are undertaken without tax implications being fully considered or where tax advice is not correctly implemented.

·       Reputational risk – the impact that our attitude to tax risk may have on relationships with all our stakeholders, including shareholders, customers, and tax authorities amongst others.

With reference to the Corporate Criminal Offence legislation, the Group has a zero tolerance attitude towards tax evasion. As part of our compliance with this legislation it is considered in the detailed risk assessments that are reviewed periodically. We ensure that reasonable risk prevention procedures are in place through our policies, processes and controls and relevant employees are subject to continual education and training.

The systems and processes the Group has in place to mitigate these risks are documented under “Governance and risk management” below.

3.      Governance and risk management

The Group aims to minimise the risks identified above by employing qualified and experienced staff and by maintaining appropriate systems and controls. The Group has used its processes for complying with the Sarbanes Oxley Act (the “Act”) as a framework for identifying and documenting where the Group could fail to pay the right amount of tax at the right time, and the necessary controls and procedures in place to address those risks. The Act was introduced in the US for publicly listed companies (and therefore also applies to their overseas subsidiaries, such as this Group) and is designed to protect investors by improving the accuracy and reliability of financial reporting. 

In this respect:

·        The Group employs qualified accountants who are responsible for covering general tax compliance matters, including annual corporation tax filings and the preparation of quarterly/annual tax calculations for financial reporting, as well as ad hoc tax queries. 

·        The qualified accountants are supported by senior management and members of Finance staff;

·        Written monthly updates are circulated to the Board on tax matters including significant tax risks and changes in legislation affecting the Group as well as any non-routine transactions with tax consequences.

·        Tax compliance is formally reviewed annually as part of the Senior Accounting Officer certification.

·        If HMRC’s internal guidance or legislation is not clear or where the Group does not have the necessary technical expertise in house to cover a particular transaction or query, the Group engages appropriate expert professional advisers and/or liaises with HMRC.

4.      Relationship with tax authorities

·        The Group aims to make fair, accurate and timely disclosure in correspondence and returns, and to respond to queries and information requests in the same manner.

·      The Group operates an open working relationship with HMRC and by aiming to identify and resolve issues promptly through dialogue.

·      Typically the Group has periodic meetings with HMRC to review compliance with taxes.

·      The Group is currently classified as low risk by HMRC and the Group aims to operate in a manner consistent with maintaining that classification.