Tax Strategy

This tax strategy is produced for Javelin Global Commodities Holding LLP and its subsidiaries (together, “Javelin” or the “Company”) in compliance with Paragraph 19(2) of Schedule 19 of the 2016 Finance Act.

This policy applies to Javelin from 31 December 2018 and will continue to apply until superseded.

Policy & Procedures

How Javelin manages tax risks

Javelin has defined policies which govern the identification and management of tax risks. These policies are in place to ensure that the Company pays the appropriate level of tax in all jurisdictions in which it operates and that identified risks are reviewed at the appropriate level within the Company. Tax policies and their implementation are overseen by the Finance group which reports directly to the Chief Financial Officer. Significant tax risks are reported to the Board of Directors.

Javelin’s attitude to tax planning

Javelin looks to operate its business in a tax efficient manner while complying with all relevant tax laws and regulations. All tax planning considers the commercial and economic substance of a transaction while looking to make use of applicable reliefs and incentives as appropriate. The Company does not enter into transactions that have no commercial purpose or to avoid taxation.

Level of risk Javelin is prepared to accept

Javelin seeks to minimise tax risk as much as possible. The Company recognizes that tax legislation can be complex especially when operating across multiple jurisdictions. When dealing with complex tax issues, the Company engages independent advisors to reduce uncertainty where possible. This includes the use of highly qualified third party firms for local transfer pricing documentation, advice on complex tax issues, and general tax advice.

How Javelin works with HMRC and other tax authorities

Javelin recognizes the importance of working closely and constructively with all relevant tax authorities. The Company pursues a positive, transparent relationship with HMRC to reduce the number of disputes and achieve quick resolutions on any disputes that may arise. To this end, Javelin is committed to providing relevant information to HMRC on a timely basis to ensure conclusions are reached as quickly as possible.