In compliance with Schedule 19 Finance Act 2016, this publication sets out the tax strategy of
Holtzbrinck Investment Limited, as the top UK holding company of the Holtzbrinck Publishing Group
and its subsidiaries and Holtzbrinck Publishing Investments Limited for the year ended 31 December
2020.
Holtzbrinck is committed to comply with all the applicable tax laws and practices in all of the countries
in which we operate. The Holtzbrinck Group operates in more than 100 countries. Key countries are
Germany, the UK and the US. Compliance means paying the right amount of taxes, in the right place,
at the right time and involves disclosing all relevant facts and circumstances to the tax authorities.
The tax affairs of the Holtzbrinck group are managed by the Global Head of Tax, who reports to the
Chief Financial Officer. The Global Head of Tax is supported by local tax teams in Germany, UK and the
US. The members of the local tax team are tax professionals that are well educated and experienced
in identification and management of tax risk. We invest in regular training to keep the members of the
tax teams properly informed about any new developments in tax legislation, and/or to further educate
themselves in specific tax areas if required or useful for the group. The local tax teams receive support
from reputable external tax advisors in their local country to ensure a proper and timely fulfilment of
the local tax reporting, filing and payment obligations and compliance with the applicable local tax
laws. Where required and appropriate the local tax teams will directly engage with HMRC and the
competent tax authorities to disclose, discuss and clarify tax issues, tax risk and uncertain tax positions.
The Global Head of Tax and local tax teams proactively manage tax issues and risk. They maintain a
close relationships with the Group’s business to be involved in projects from planning to
implementation to ensure that potential tax risks are identified in advance, and appropriate tax
treatment is applied. Potential tax exposures are managed, tax guidance provided is followed and
clear and timely guidance is given to the Group’s business managers on any tax matter that may arise.
The business understands that the tax teams need to be involved in any transaction at an early stage
and fully cooperates with the tax teams.
Our company has in place such policies and procedures that are reasonable to prevent the offences of
UK and foreign tax evasion facilitation under sections 45(1) and 46 (1) of the Criminal Finances Act
2017.
Holtzbrinck falls under the Senior Accounting Officer (SAO) certification regime in the UK. As part of
this, the UK-related tax processes will be reviewed annually in order to provide assurance for the
certification. In Holtzbrinck’s other key countries, Germany and the US, Holtzbrinck is subject to a
regular and ongoing audit by the tax authorities.
Holtzbrinck’s key objective in terms of tax planning is to ensure full compliance with the tax regulations
of all the countries in which it operates and to properly and timely fulfil any reporting and filing
obligation and to pay the correct amount of any taxes on a timely basis.
We do not consider and engage in aggressive tax planning and artificial arrangements. Our tax planning
is aligned with our commercial business activities and based on the principle that profits are allocated
and taxed in the countries in which business value is created. Based on this principle and in compliance
with the local tax laws we consider it our responsibility to our shareholders to structure our affairs and
business transactions in a tax efficient manner. Accordingly we make use of tax reliefs, exemptions,
allowances and incentives where available and in a manner intended by the applicable tax laws. We
will not use tax planning for purposes which are knowingly in contradiction with the intent of the tax
laws.
Within our tax planning we aim for certainty on the tax positions and interpretations of the applicable
tax laws we adopt. Where the tax law is unclear or subject to interpretation or where different
alternatives with a different tax outcome exist, we may seek advice from a reputable external tax
advisor and/or discuss the matter directly with HMRC or the competent foreign tax authority to
confirm our position adopted.
Holtzbrinck’s appetite for tax risk is low. We seek to be compliant with the tax laws and to minimise
the risk of a dispute with HMRC and foreign tax authorities by being open, transparent and honest
about all our tax affairs.
We do not engage in artificial tax arrangements, to avoid taxes. Any tax planning and tax optimisation
activities are compliant with the applicable tax laws, are supported by solid business reason and are
consistent with commercial reality.
Given the nature, scale and internationality of Holtzbrinck’s business tax risk are to a certain extent
inevitable in the current international environment. However, we actively seek to identify, evaluate,
monitor and manage this tax risk. Where there is significant uncertainty surrounding the interpretation
of law or complexity in relation to a tax risk, we will seek external advice from reputable external tax
advisors and/or seek to resolve the uncertainty by dialogue with HMRC or the competent foreign tax
authorities.
It is Holtzbrinck’s aim to maintain an open, transparent, honest, collaborative and constructive working
relationship with HMRC. Within the Senior Accounting Officer process, we have a regular meeting with
HMRC through our Customer Compliance Manager in which we disclose and discuss with HMRC any
developments in the Group’s business, changes in the Group’s structure, tax risk, tax issues and status
of the fulfilment of our tax filing, tax reporting and tax payment obligations as well as compliance with
any new tax legislation. The UK group has a large business relationship with HMRC and this results in
a formal risk assessment of the group by HMRC on a triennial basis. The group currently enjoys a Low
Risk Rating.