Tax strategy

SG Fleet UK Tax Strategy

Introduction and scope

This Tax Governance & Strategy Policy (‘Policy’) describes the overarching governance policy the SG Fleet UK business operates in relation to the management of its tax obligations, ensuring compliance, transparency and ethical conduct in all tax-related matters.

This policy applies to the following UK legal entities; SG Fleet UK Holdings Limited, SG Fleet Solutions UK Limited, SG Fleet UK Limited and Fleet Hire Holdings Limited. Collectively referred to as ‘the UK Business’ or ‘UK Businesses’. The UK Businesses are subsidiaries of SG Fleet Topco Pty Limited (subsequently referred to as ‘the Group’)

The Group, along with its subsidiaries is a leading provider of integrated mobility solutions, including fleet management, vehicle leasing and salary packaging services. The Group has a presence across Australia, the United Kingdom and New Zealand.

This Tax Strategy is published in accordance with paragraph 16(2) of Schedule 19 to the Finance Act 2016. The UK Businesses regard the publication of this version of the strategy as satisfying that obligation for the financial year ending 30 June 2027. This strategy applies from the date of publication until it is superseded.

This strategy applies to all UK taxes and duties applicable to the UK Businesses. References to ‘UK Taxation’ are to the taxes and duties set out in paragraph 15(1) of the Schedule which include Income Tax, Corporation Tax, PAYE, NIC, VAT, Insurance Premium Tax, and Stamp Duty Land Tax. References to ‘tax’, ‘taxes’ or ‘taxation’ are to UK taxation.

This Tax Strategy has been approved by the Boards of each of the UK Businesses and will be reviewed annually by the Executive Risk Committee. The Boards of the UK Businesses are ultimately accountable for tax governance and oversee the implementation of this strategy. Any amendment will be subject to approval from the relevant Boards and Committees.

Our approach to tax

The UK Businesses will manage their tax affairs in line with the following objectives:

• To fully comply with both the letter and intent of the tax laws in the jurisdictions in which we operate, and to engage with the revenue authorities (HMRC) in a transparent manner, providing full and accurate disclosure at all times,
• Pay the right amount of tax having regard to the underlying commercial operations, available incentives and reliefs and the tax risk appetite established by the Board,
• Operate within its values and support its core and strategic objectives by being a socially responsible taxpayer,
• Have the Finance function regarded as an integral part of how we conduct business,
• Continue to align and update the strategic tax objectives to reflect our overall corporate strategy,
• Apply appropriate resources (internally or externally), in the management of our taxation position,
• Recognize that tax laws and regulations are evolving and that there is public and other stakeholder interest in the management and payment of tax by organizations.
• Maintenance of documented policies and procedures in relation to tax risk management and completion of thorough risk assessments including escalation and reporting to the Directors where prescribed.

This Tax strategy provides a governance structure to enable the UK Businesses to comply with current tax obligations and remain compliant in the ever-changing environment.

Governance arrangements

The Group has the ultimate responsibility for corporate governance and the establishment of a tax control framework, which includes the UK Business. The Group structures include an Audit, Risk & Compliance Committee and a Tax Governance Committee. Within this framework a specific UK Executive Risk Committee operates which is responsible for oversight and monitoring risk, including tax risk management and compliance with policies and frameworks.

Ultimate responsibility for the operation of the UK Businesses’ tax affairs rests with the UK Finance Director, who has been appointed by the UK Businesses as the Senior Accounting Officer (SAO).

The Finance Director is responsible for ensuring compliance with tax laws and regulations, including filing and payment obligations in a timely manner, managing relationships with revenue authorities, responding to regulator queries on tax matters and ensuring records and controls are in place to keep tax registrations up to date and meet data keeping obligations.

Authority to manage the day-to-day tax affairs of the UK Business is delegated to the UK Finance team, comprised of appropriately qualified and experienced personnel. External Tax advisers are also utilised and engaged and assist in the preparation and finalisation of Corporate Tax returns and provide advice and support in relation to other HMRC filing obligations.

The Governance structures also include a Group Senior Risk Manager and an Internal Audit Function. The Internal Audit function is responsible for control reviews, testing programs and reporting of results to the relevant Boards / Committees.

Tax risk management

The Group has a tax risk management framework which applies to the UK Business, this aligns with the Group Risk Management Policy and Risk Appetite Statements.

The UK Businesses’ general principles on tax risk management are:

• Taxation positions and any related risks will be taken consistent with the risk tolerance levels set out in our Tax Framework and Policies,
• Reputational risk ranks alongside tax technical risk when assessing the adoption of tax positions,
• Tax risk is assessed proactively at the front-end of transactions, changes in business and IT systems and post-implementation,
• Processes relating to different taxes are allocated to appropriate process owners, who carry out a review of activities and processes to identify key risks and mitigating controls in place. These key risks are monitored for business and legislative changes which may impact them and changes to processes or controls are made when required, 
• Appropriate training is carried out for staff who manage or process matters which have tax implications, and
• Advice is sought from external advisers and from the Group Tax Function, if required and where appropriate.

Below is a summary of the three lines of defence we operate for tax risk management:

• Taxation positions and any related risks will be taken consistent with the risk tolerance levels set out in our Tax Framework and Policies,
• Reputational risk ranks alongside tax technical risk when assessing the adoption of tax positions,
• Tax risk is assessed proactively at the front-end of transactions, changes in business and IT systems and post-implementation,
• Processes relating to different taxes are allocated to appropriate process owners, who carry out a review of activities and processes to identify key risks and mitigating controls in place. These key risks are monitored for business and legislative changes which may impact them and changes to processes or controls are made when required,
• Appropriate training is carried out for staff who manage or process matters which have tax implications, and
• Advice is sought from external advisers and from the Group Tax Function, if required and where appropriate

Below is a summary of the three lines of defence we operate for tax risk management:

• The UK Finance Director and UK Finance Team (1st line of defence) are responsible for managing tax risk within their area of control and are accountable for ensuring that significant tax risks are appropriately identified and managed,
• The UK Risk & Compliance function and UK Executive Risk Committee (2nd line of defence) facilitates appropriate segregation of duties between tax risk management and tax risk monitoring,
• Internal Auditors and External Auditors (3rd line of defence) provide further independent oversight and assurance.

Below sets out our approach to tax risk monitoring:

• A tax risk register is maintained detailing all identified tax risks.
• All Risks are assigned a Residual Risk rating, with detailed management actions being captured where further risk mitigation is required.
• The Tax Risk Register is required to be monitored and reviewed by management and presented at the Executive Risk Committee on at least an annual basis.
• An attestation register exists which captures all HMRC filing deadlines, which are monitored to ensure timely submission of all returns.

These risk management processes set out above provide assurance that the requirements of our Tax Policy and Governance Frameworks are being met.

Attitudes to tax planning and acceptable risk

The wider Group and the UK Business has a conservative tax risk appetite for anything that would compromise achievement of its tax objectives. This means that:

• No aggressive or unacceptable tax positions are taken,
• An opinion from an external tax advisor or clearance from a revenue authority (e.g., a ruling) is obtained for significant or material tax related matters,
• The level of opinion provided must be commensurate with the level of risk. At a minimum all external opinions should at least confirm that the desired outcome is a ‘should’ level of opinion for a risk rated as ‘high’,
• We will not enter into artificial arrangements designed to avoid taxation or defeat the intended purpose of tax legislation,
• All transactions and operations must have a business purpose or commercial rationale, and
• We will only take positions we would be able to explain and substantiate to the relevant taxation authority.

Relationships with HMRC

In line with our Group wide Tax Governance Policy, the UK Businesses seek a transparent and cooperative approach with HMRC.

We will engage with HMRC with high standards of honesty, integrity, and ethics in the spirit of cooperative compliance and will proactively correspond with HMRC. We will also work to answer any queries or resolve any differences in a timely and professional manner, aiming to respond to enquiries by due dates and cooperating fully in our engagement.

This policy was last updated on 21st August 2026.