UK Tax Strategy Statement

1. Introduction

This strategy applies to all UK entities of TMF Group, has been prepared in accordance with Part 2 of Schedule 19 Finance Act 2016 and is effective for the financial year ended 31 December 2024. This strategy is reviewed annually by the Board of Directors of TMF Group Ltd.

2. Governance and Tax Risk Management

The Chief Financial Officer has the overall responsibility for tax governance in relation to UK taxation and has delegated the day-to-day responsibility to the Group Tax Director.

Oversight and approval are provided by the Board of Directors of the respective UK entities. Significant tax related matters are reported by the Group Tax Director to the relevant Board of Directors.

The Group Tax Team manages UK tax compliance, reporting, and advisory matters, supported by local finance teams and reputable external tax advisors where appropriate. Key processes and controls, including clearly defined roles and responsibilities, are in place to ensure compliance with UK tax laws and identify, quantify and manage UK tax risks.

3. Attitude Towards Tax Planning

TMF Group believes that tax should follow the business. This means that we do not conduct transactions that are artificial and not driven by commercial considerations, are not aligned with business activity, and which have no genuine substance.

We apply the arm’s length principle in line with the OECD Transfer Pricing Guidelines and our transfer pricing policies are aligned with the economic activity of our business.

TMF Group only engages in tax planning that supports genuine commercial activity and complies with UK tax law. We seek to utilize available tax incentives, reliefs, and exemptions, where appropriate and in line with the UK tax law.

External tax advice is sought for material and/or complex transactions to ensure compliance and transparency.

4. Risk appetite

TMF Group aims to be fully compliant with tax laws and regulations. This includes making sure that tax fillings are on time, accurate and complete, as well as tax payments are made in full and on time.

We also act in line with letter and spirit of the law, while it is recognized that there could be a certain level ambiguity as to the interpretation of the letter and spirit of the law.

TMF Group’s risk appetite towards taxes is low. We seek to minimize uncertainty through robust documentation and external professional advice. Where ambiguity exists, we aim to resolve it through disclosure and dialogue rather than litigation.

5. Relationship with HMRC

TMF Group seeks to build and maintain a transparent, collaborative and constructive relationship with HMRC based on mutual integrity and trust.

We provide HMRC with all relevant information in a timely and accurate manner to facilitate efficient tax compliance.

TMF Group aims respond to queries from or resolve disputes with HMRC in an open and cooperative way, seeking to achieve certainty where possible.