This document is published in accordance with Part 2 of Schedule 19, Finance Act 2016, following the latest annual review of and with the approval of the Board of Directors of John Clark (Holdings) Limited (SC098411) on 15/09/2025.
This strategy covers the period ending December 31st 2025.
STRATEGY
John Clark (Holdings) Limited and our wholly owned subsidiaries (known as “John Clark Motor Group” or “JCMG”) is committed to acting with integrity and transparency in all tax matters.
GOVERNANCE & RISK MANAGEMENT
Tax Governance is a core part of the central support duties of the Group Finance team based at our Head Office in Aberdeen and it is the ultimate responsibility of the Group Finance Director to ensure that the above tax strategy and policy is followed in his role as Senior Accounting Officer.
The Tax strategy and policies are reviewed on an on-going basis by the Group Finance Team and Board of Directors where necessary. Tax strategy and policy issues and/or any changes in tax legislation from the UK Government, are monitored and assessed by the Group Finance Director and our central finance team. Reviews of key issue updates are provided by our tax, audit and property advisers, where these are duly considered and acted upon if appropriate.
Day-to-day tax matters are delegated to the Group Finance team along with the support of our divisional and dealership accountants. Internal and external audit reviews are also supported.
We strive to make timely and accurate tax returns for, and payments of, all relevant taxes including Corporate, Employment, Property and Indirect e.g. Value Added Tax, that duly reflect our fiscal obligations to the UK Government, the Scottish Parliament and to local Councils. Where any variances or queries arise, we seek to promptly review and respond to these.
Recognising that our operations are based wholly within the United Kingdom, our tax strategy and policies require that our dealerships fully comply with all appropriate UK tax law.
To support us in ensuring that we have understood and interpreted both the drafting and the spirit of tax law correctly, we seek advice from our tax, accounting, property and legal advisers. All of which we ensure are leading, highly respected and reputable firms which are suitably qualified and experienced to provide us with the required level of professionalism. To best support the independence of our key advisors, we have appointed two separate firms as our auditor and as our tax adviser.
We are committed to maintaining robust systems and controls to manage our tax risks effectively across all areas of our business. Our approach to tax risk management is integrated within our wider corporate governance framework and is designed to ensure compliance with all relevant UK tax legislation and regulations.
Our key tax risks are identified and assessed on an ongoing basis, with appropriate controls and procedures in place to mitigate these risks. We utilise standardised systems and processes across the group to support the accuracy and integrity of our tax reporting, including some key areas which are specific to our sector. For example :-
A. Our main IT infrastructure is a motor trade bespoke system, which applies standardised group wide reports and controls. Given our VAT Group status, this supports an inter-branch used vehicle transfer system which ensures that VAT margin scheme details transfer with the car. Thereby minimising the risk of error in this motor trade specific issue.
B. Our fully in house payroll process utilises a well known, widely used and proven IT system for all PAYE/NIC calculations, with then central coordination of payroll reports and PAYE/NIC remittance as well as National Living Wage rate reviews and monitoring controls - including as appropriate apprentice age related uplifts. Thereby minimising the risk of error in these areas.
We recognise our obligations under the Criminal Finances Act 2017, including the Corporate Criminal Offence of failure to prevent the facilitation of tax evasion. In line with the guiding principles set out in the legislation, we have implemented proportionate prevention procedures and communication to ensure awareness and compliance throughout the organisation. We identified our key sector specific risks as associated with vehicle sales transactions across (1) Anti-money laundering checks including Covid 19 Bounceback loan fraud, and (2) VAT fraud associated with zero rated vehicle sales which see conversion for use by those with disabilities,
Regular reviews and updates of our controls are undertaken to ensure they remain effective and reflect any changes in our business operations or the external environment.
Our governance structure ensures that tax risks are monitored and managed at all levels, with oversight from both operational and senior management teams. We are committed to continuous improvement in our tax risk management processes and to maintaining an open and transparent relationship with HMRC.
TAX PLANNING
The Group only engages in tax planning that is aligned with commercial and economic activity. We do not enter into artificial arrangements for the purpose of tax avoidance.
The Group is committed to paying the amounts of tax that fall legally due in the UK and does not enter into any transactions designed to secure an unfair tax advantage. We do not operate any non-UK based companies, corporate trusts or bank accounts.
We understand the value of our financial reporting to customers, investors and other stakeholders. We work to provide enhanced, transparent and balanced disclosure in communicating our tax affairs.
Where necessary, due to the complex nature of tax legislation, appropriate external advice is sought to support the business decision making process. The Group sees the input of external advisers as a source of specific tax expertise to supplement the skills of our own finance team.
APPROACH TO TAX RISK
The Group has a low tolerance to tax risk and will seek to reduce tax risk as far as practically possible through adherence to this strategy, consultation with external advisers, and where appropriate seeking clearances from HMRC.
RELATIONSHIP WITH H.M. REVENUE & CUSTOMS (“HMRC”)
We are committed to maintaining an open, honest, and constructive relationship with HMRC, seeking to resolve any issues in a timely and cooperative manner.
An important part of our tax strategy and policies is to maintain and further development of a proactive working relationship with HMRC, particularly with our Edinburgh based HMRC Customer Compliance Manager. We are transparent with HMRC and seek to ensure that they are kept informed of key developments in our business, as well as any notable changes in our seasonal trading led payment patterns.
We seek to participate in and learn from HMRC update(s) webinars as well as, where and when appropriate, provide supporting attendance at and input into motor trade specific briefings.
Where received, once duly verified as in accordance with the Data Protection Act, we promptly support a response to any customer information requests from HMRC and/or a UK Police force.
On 17 November 2022, the UK Government confirmed its intention to implement the G20-OECD Inclusive Framework Pillar 2 rules in the UK. The legislation was substantively enacted on June 2023. Whilst the Group is wholly UK incorporated as well as UK tax resident and is not tax resident in any other jurisdiction, we have duly completed the HMRC registration process.
