Portman Travel Group Limited – Tax Strategy December 2022 Scope:

The Portman Travel Group Limited is a Limited Group incorporated and registered in England and Wales. The group is wholly owned by Seera (Formally Al Tayyar) a company registered in the Kingdom of Saudi Arabia.

The strategy outlined in this document applies to the Portman Travel Group Limited (PTGL) and to the group of companies headed by PTGL in accordance with paragraph 19 and 25 of Schedule 19 to the Finance Act 2016. In this strategy references to the Portland Travel Group Limited (PTGL), or the ‘Group’ applies to all UK subsidiaries of PTGL. The strategy in accordance with paragraph 17(4) of the Schedule has been published on Clarity and Elegant websites. The strategy applies from the date of publication until it is superseded.

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 and to all corresponding worldwide taxes and similar duties in respect of which PTGL has legal responsibilities.

Risk Management:

– PTGL seeks to reduce the level of tax risk arising from its operations as far as is reasonably practicable by ensuring that reasonable care is applied in relation to all processes which could materially affect its compliance with its tax obligations;

– Processes relating to different taxes are allocated to appropriate process owners, the Finance departments at entity level are responsible for VAT returns and the calculation and deduction of payroll taxes (including benefits) are managed within the Human resources department. These key risks are monitored for business and legislative changes within the Central Finance department, which may impact them and changes to processes or controls are made when required;

– Advice is sought from external advisors on all tax matters that may arise during the course of the financial period that require expert knowledge. External advisors are also responsible for the preparation of annual Corporation tax returns based on the tax information supplied by the finance teams.

Attitude towards tax planning and level of risk:

PTGL manages risks to ensure compliance with legal requirements in a manner which ensures payment of the right amount of tax.

At all times PTGL seeks to comply fully with its regulatory and other obligations and to act in a way which upholds its reputation as a responsible corporate citizen.

The Board is ultimately responsible for identifying the risks, including tax risks, which need to be addressed and for determining what actions should be taken to manage those risks, having regard to the materiality of the amounts and obligations in question.

The Group seeks to arrange its affairs with the support of external advisors, in such a way as to ensure that it maximises all available claims and reliefs under UK tax legislation and in the manner in which the legislation was intended.

The Group will continue to have a strong focus on compliance with all applicable tax legislation. Where specialist advice on tax matters is required, the Group will liaise with HMRC to discuss appropriate tax treatment. When assessing the level of any remaining risk, the Group will take a prudent approach to the issue and take additional external advice as appropriate.

Relationship with HMRC:

The Group is committed to working collaboratively with HMRC, through open and transparent dialogue to ensure it is compliant with all of its compliance and filing obligations. The Group has a proactive working relationship with HMRC and will continue to engage with HMRC on a real-time basis. Any inadvertent errors in a submission made to HMRC are fully disclosed as soon as reasonably practicable after they are identified.