UK Tax Strategy
This document sets out the UK tax strategy of NRL Group (the “Group”) for the financial year ending 31 December 2026. It is published to meet the requirements of Schedule 19, Finance Act 2016 in respect of UK taxation for the Group, which has UK turnover in excess of £200 million.
This strategy applies to all UK entities within the Group and to all UK taxes and duties, including (but not limited to) corporation tax, PAYE, NIC, VAT, insurance premium tax, customs and excise duties, and stamp taxes. It is aligned with the Group’s wider business strategy, risk framework and governance arrangements and is approved by the Board of Directors of NRL Group Limited.
2. Tax risk management and governance
The Group is committed to robust tax governance, appropriate systems and controls, and accurate and timely tax compliance in all jurisdictions in which it operates. Overall responsibility for tax risk and this strategy rests with the Board, which delegates day‑to‑day management of tax matters to the Chief Financial Officer and the Senior Accounting Officer (“SAO”), supported by the finance and tax teams.
The Group operates a documented tax risk management framework that is integrated into its overall internal control environment. Key features include:
- Clear allocation of roles and responsibilities for tax within the finance function and documented processes for key tax cycles (e.g. corporate tax provisioning, VAT reporting, payroll).
- Regular reporting of material tax issues and risks to the Risk Committee and Board, including any significant judgements, disputes or changes in law.
- Use of external professional advisers where appropriate, particularly in areas of complexity, uncertainty or significant transaction activity.
In accordance with the SAO regime, the appointed SAO provides an annual certification to HM Revenue & Customs (“HMRC”) that the Group’s tax accounting arrangements are appropriate, or explains any material deficiencies identified.
The Group’s approach is to pay the right amount of tax at the right time in accordance with both the letter and the spirit of UK tax law. The Group does not engage in artificial or aggressive tax planning that lacks commercial substance or is inconsistent with its business activities or brand values.
Tax planning is undertaken to support genuine commercial transactions and to ensure tax efficiency within the boundaries of UK legislation and relevant OECD principles. The Group seeks to make use of available reliefs and incentives (for example, capital allowances, R&D and other statutory reliefs) where they are aligned with commercial activity and the intent of Parliament. Any planning that could materially impact the Group’s tax profile is subject to review by suitably qualified internal personnel and, where appropriate, external advisers, and may be escalated to the Board or Risk Committee for approval.
4. Level of tax risk the Group is prepared to accept
The Group has a low appetite for tax risk and does not seek to take positions on tax matters that are inconsistent with the Group’s understanding of legislation, case law or HMRC guidance. However, given the inherent complexity of tax law and the scale of the Group’s operations, some degree of tax risk is inevitable.
Where the tax treatment of items is uncertain, the Group will form a view that is reasonable, supportable and consistent with applicable law and guidance, and will reflect any uncertain tax positions in its financial statements in accordance with relevant accounting standards. The Group aims to reduce tax risk by:
- Maintaining high‑quality tax processes, controls and documentation, including contemporaneous evidence of significant judgements and tax positions.
- Seeking advance clearances or non‑statutory clearances from HMRC where appropriate.
The Group aims to maintain an open, professional and collaborative relationship with HMRC. The Group seeks to be transparent in its dealings with HMRC, providing relevant information in a timely manner and responding to queries promptly, accurately and courteously.
Where significant transactions or developments arise, the Group seeks to discuss relevant tax implications with HMRC on a real‑time basis where appropriate, particularly where the tax treatment is uncertain or may be material. The Group aims to resolve any areas of disagreement with HMRC constructively and, where differences of opinion arise, will seek to achieve resolution through discussion and agreement rather than litigation, while reserving the right to defend its position where it believes it is correct in law.
6. Review, approval and publication
This UK tax strategy is reviewed at least annually and updated as appropriate to reflect changes in the Group’s business, tax risk profile or applicable law and guidance. It has been approved by the Board of Directors of NRL Group Limited on 22nd December 2025 and is published on behalf of all UK entities within the Group in accordance with paragraph 16(2) / paragraph 19(2) of Schedule 19, Finance Act 2016, as applicable.
This strategy is intended to satisfy the Group’s duty to publish its UK tax strategy in respect of the financial year ending 2026 and remains available free of charge on the Group’s website until superseded by a subsequent version.