Tax principles

JFS is committed to managing its tax affairs in a responsible and transparent manner, to comply with all relevant tax legislation and to have due regard for the Group’s wider reputation and its corporate social responsibilities. Whilst the Group has a duty to shareholders to seek to minimise its tax burden, its policy is to do so in a manner which is consistent with its commercial objectives, meets its legal obligations and its code of ethics.

JFS considers that financial crime is unacceptable and it does not tolerate criminal tax evasion, nor deliberate or dishonest facilitation of another party’s tax evasion carried out by anyone acting on the Group’s behalf. It is our policy to refuse to transact business with parties who we consider may be engaging in tax evasion.  

The Group aims to manage its tax affairs with regard for the intention of the legislation rather than just the wording itself. Our tax objectives are to comply with all applicable tax laws and regulations, including the timely submission of all tax returns and tax payments and to undertake all dealings with local tax authorities in a professional and timely manner. Substantial tax revenues (including payroll taxes) are generated by the Group’s operations worldwide.  

Governance and risk management

The Board has ultimate responsibility for tax governance. Executive responsibility rests with the Group Finance Director who reports to the Board as required.

The Group has a dedicated in-house tax function that deals with the Group’s day to day tax management issues and with UK corporation tax compliance. External tax agents are appointed to deal with corporate income tax compliance in foreign tax jurisdictions.

Certain tax responsibilities (e.g. VAT) are devolved to individual business units. These units are required to comply with Group policies and financial controls and certify compliance to the Group Finance Director.

The tax strategy is communicated to personnel within the business who play a part in the delivery of the strategy. Supervision, training and guidance is provided to staff who have tax related responsibilities.

If matters of uncertainty arise in relation to the application of tax law the approach is to seek to resolve that by taking external professional advice or dialogue with the relevant tax authority.

External professional tax advice is obtained in areas and geographies where additional expertise is required in order to comply with legislation and ensure taxes are correctly computed and paid. JFS also holds regular meetings with its tax advisers, the Group tax function and Business Finance Directors to discuss key risks and issues for the Group.

Level of tax risk

Risk appetite is not defined in numerical terms. In view of the policy objective to be tax compliant and the limitations on tax planning described below JFS considers that it has a low tax risk appetite.

Attitude towards tax planning

The Group has obligations to shareholders and thus the tax strategy does not rule out legitimate tax planning. Planning opportunities that are regarded as consistent with commercial objectives and which are likely to benefit shareholders may be considered. Opportunities may be pursued provided they do not represent a serious threat to the Group’s reputation nor must they damage relations with regulatory authorities. It is Group policy not to undertake any tax planning transaction that would reflect adversely on JFS. The Group’s tax advisers are asked to review, advise on and approve any significant tax planning measures. The Group’s policy is not to seek to take advantage of arrangements which are intended to give rise to tax effects substantially inconsistent with the economic substance.

Dealings with tax authorities

We seek to maintain a good working relationship with tax authorities and deal with them in an open, transparent and timely manner. All reasonable cooperation will be given in relation to audits and enquires.

Approval:

This strategy was approved by the JFS Board on 4 November 2021 and will be reviewed annually.