This Tax Strategy document sets out the approach of Trailfinders Group Limited (“TGL”), and its trading subsidiaries, (“the Trailfinders Group” or “the Group”), as it relates to UK taxation.

This document is published by Trailfinders Group Limited, the ultimate parent company of the Trailfinders Group, on behalf of all the relevant group companies, following formal approval by the Board of Directors.

This Tax Strategy document has been prepared in accordance with the requirements of Schedule 19 of Finance Act 2016 and specifically paragraph 16(2) of that Schedule.

Experts with the highest levels of integrity in tailor-making itineraries worldwide, the Trailfinders Group is a multi-award winning organisation founded in 1970 by former SAS officer Sir Mike Gooley CBE. The Trailfinders Group remains wholly-owned by Sir Mike Gooley CBE, and employs over 1,000 staff across 47 travel centres, staffed by the most expert travel consultants in the industry.

The active trading subsidiaries of the Trailfinders Group are:

• Trailfinders Ltd (incorporated in England)
• Trailfinders Ireland Ltd (incorporated in Ireland)
• Trailfinders Pty Ltd (incorporated in Australia)
• W8 Catering Ltd (incorporated in England)

In accordance with paragraph 16(4) of Schedule 19 FA 2016, this Tax Strategy has been published as a standalone document and is freely available to external stakeholders via the Trailfinders' website.

The Tax Strategy relates to the financial year ended 29 February 2024 and shall be effective from the date of publication until it is superseded or otherwise replaced and shall apply to UK taxation as prescribed by Paragraph 15 Schedule 19 Finance Act 2016.

The approach of the Trailfinders Group to risk management and governance arrangements in relation to UK taxation.

The Trailfinders Group is committed to full compliance with all aspects of UK taxation and applies the same standards in all jurisdictions in which the Group operates.

Whilst the overall responsibility for UK taxation oversight governance and the implementation and adherence of the Tax Strategy rests with the Board of Directors, the day-to-day management of UK taxation is conducted by the Finance Director (“FD”). The FD is authorised to make decisions relating to the Group’s tax affairs, including, but not limited to, the approval of tax filings submitted to HM Revenue & Customs (“HMRC”) and other relevant tax authorities.

The FD is also the formally appointed Company Secretary of TGL and serves as both a Director and Company Secretary of the Group’s largest trading entity - Trailfinders Limited.

To ensure the correctness and completeness of tax compliance filings and payments, the Group has established a system of internal controls and processes designed to minimise the risk of errors in relation to UK taxation. This system is subject to regular internal and external review, including audits and HMRC oversight, and is updated as necessary in response to changes in legislation or tax guidance which may have an impact on its operation.

Through the consistent application of these controls, the Trailfinders Group seeks to minimise tax risk arising from its commercial operations by exercising reasonable care, particularly with respect to transactions that could have a material impact on its tax obligations.

The Trailfinders Group is subject to, and adheres to, HMRC’s Business Risk Review process. In line with this, there is a focus on the following key objectives:

• To maintain tax accounting arrangements suitable to the Group’s operations;
• To make correct payments of tax, including estimated payments on account, when falling due;
• To make any necessary disclosures to HMRC and the relevant regulatory body; and
• To make timely filings of relevant tax returns.

As a matter of practice, the Trailfinders Group is supported by professional tax advisors and obtains professional tax advice for complex matters and transactions outside the normal course of business. Such advice is reported to the Board of Directors for consideration and oversight.

The Trailfinders Group also engages external advisors to prepare and submit annual corporation tax returns and provide advice relating to the payment of corporation tax to HMRC.

The attitude of the Trailfinders Group towards tax planning

The Trailfinders Group adheres to the principles of integrity in all commercial dealings including UK taxation matters.

The Trailfinders Group does not engage in artificial tax planning arrangements whose sole purpose is to reduce the level of tax payable. With regards to UK taxation, the Trailfinders Group ensures that all transactions are accounted for in line with their underlying commercial rationale and in compliance with relevant legislation.

Where uncertainty exists regarding the appropriate tax treatment of a transaction, the Group seeks external professional advice and applies that advice as appropriate. In cases where genuine alternative tax treatments may exist for any commercial transaction, the Group will adopt the most tax efficient approach provided it complies with all applicable existing legislation and aligns with the Group’s wider objectives.

Where eligible and approved by HMRC, the Trailfinders Group will take advantage of tax incentives, reliefs and exemptions as set out in UK legislation.

The level of tax risk that the Trailfinders Group is prepared to accept

The Trailfinders Group has a low tolerance for tax risk.

The Trailfinders Group’s conservative attitude towards tax risk is primarily governed by the Board of Directors’ overarching objective to minimise any and all commercial tax risk. Accordingly, the Group adopts a prudent approach to tax matters, ensuring risk is appropriately mitigated by adhering to UK tax legislation and maintaining full transparency, including proactive engagement with HMRC on any material risks identified.

At all times, The Trailfinders Group aims to fully comply with its UK taxation obligations and to act in a manner that upholds its reputation of corporate responsibility, consistent with its values and charitable commitments.

The approach of the Trailfinders Group towards its dealings with HMRC

The Trailfinders Group operates under HMRC's Large Business customer relationship model, which is based on the principles of "mutual trust, transparency and resolving issues in real time". The Group fully adheres to these principles.

HMRC originally published a draft Framework for Cooperative Compliance for Large Business, and this which was subsequently incorporated into their Tax Compliance manual on 9 May 2022. This framework outlines best practices in tax governance for large organisations.

The Trailfinders Group's Tax Strategy is aligned with this framework and includes the following commitments:

• Promoting collaborative and professional working with HMRC to build an open, transparent, and trusted relationship;
• Engaging in open and early dialogue with HMRC to discuss tax planning, strategy, risks, and significant transactions, including full disclosure of any material uncertainty;
• Responding to HMRC queries and information requests in a timely manner;
• Seeking to resolve issues in real time and, where possible, before tax returns are filed;
• Making fair, accurate, and timely disclosures in all relevant returns and documentation;
• Working with HMRC to resolve any disagreements by agreement where possible;
• Maintaining transparency in decision-making, governance, and tax planning, ensuring HMRC is informed of who holds responsibility and how decisions are made;
• Avoiding the structuring of transactions in ways that produce tax results inconsistent with their economic substance, unless permitted by specific legislation;
• Interpreting tax law reasonably and structuring transactions in line with cooperative compliance principles;
• Applying an “openness and early dialogue” approach to clearly identify specific tax risks, thereby avoiding unnecessarily broad enquiries;
• Discussing risks and transactions on a real-time basis (i.e. pre-transaction or pre-return).

As a result, the Trailfinders Group has regular and constructive interactions with HMRC. The Group proactively addresses any areas of uncertainty and, where necessary, makes appropriate disclosures in its tax submissions. In the event that any errors are identified, the Group takes immediate action to correct them and makes full disclosures as required.

The Trailfinders Group is also within the scope of the Senior Accounting Officer (“SAO”) legislation, as set out in Schedule 46 of the Finance Act 2009, which requires an annual declaration confirming that appropriate tax accounting arrangements are in place, supported by robust governance and systems.

In the Financial Year ending 29th February 2024, the Group paid the following amounts to UK Government agencies:

• Corporation Tax: £9.1m
• Employer National Insurance Contributions of £5.3m
• Council Tax and Business Rates of £1.8m
• ATOL fees of £0.1m
• Apprenticeship Levy of £0.2m
• Air Passenger Duty of £20.0m
• PAYE of £9.0m
• Employee National Insurance Contributions of £3.1m

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Updated by Lawrence Comber, 25th June 2025

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