UK Tax Strategy

August 26, 2020

This strategy applies to Molson Group Limited and the entities listed at Appendix 1 collectively referred to as “Molson Group” in this strategy, in accordance with paragraph 19 of Schedule 19 to the Finance Act 2016. The strategy has been published in accordance with paragraph 19(4) of the Schedule.

This strategy applies from the date of publication until it is superseded.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 the Molson Group has legal responsibilities.

Molson Group Tax strategy is underpinned by key policies below to ensure that we are a responsible corporate tax citizen.

Aim

Molson Group strives for full compliance with all statutory obligations and full disclosure to relevant tax authorities. The group’s tax affairs are managed in a way which takes into account the group’s wider corporate reputation in line with Molson Group’s overall high standards of governance, core ethical behaviours and values

Governance in relation to taxation

  • Ultimate responsibility for Molson Group’s tax strategy and governance rests with the Board of Directors (“the Board”)
  • Responsibility for governance for all matters relating to taxation is delegated to the Finance Director.
  • The Regional Board ensures that tax strategy is one of the factors considered in significant investments and business decisions taken.
  • The Group Finance Director reports to the Board on tax affairs and risks.
  • Local management of each legal entity is responsible for ensuring that all applicable regulations as well as internal guidelines and governance procedures relating to taxation are observed.
  • The Molson Group is staffed with appropriately qualified individuals.

Risk Management

  • Molson Group operates a system of tax risk assessment and controls as a component of the overall internal control framework.
  • Processes relating to different taxes are reviewed regularly in order to identify key risks and implement mitigating internal controls. These key risks are monitored for business and legislative changes which may impact them and changes to processes or controls are made when required.
  • Potential tax risks are assessed and processes and controls are implemented to mitigate the risks to an acceptable low level.
  • Internal control procedures and processes are subject to regular reviews, internal audits and self-assessment programs.
  • Advice is sought from external advisers where appropriate.

Attitude towards tax planning and level of risk

  • Molson Group manages risks to ensure compliance with legal requirements in a manner which ensures payment of the right amount of tax.
  • Molson Group does not engage in artificial tax arrangements, i.e. planning that is not underpinned by commercial and economic substance. Tax planning measures are always in line with the tax legislation with a low risk of non-acceptance by Tax Authorities. Advice is sought from external advisers where uncertainty exists.
  • When entering into commercial transactions, Molson Group seeks to utilise available tax incentives, reliefs and exemptions in line with and in the spirit of tax legislation.
  • At all times Molson Group 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.

Relationship with HMRC

  • Molson Group has a transparent, open and constructive relationship with HRMC.
  • Molson Group ensures that Tax Authorities are kept aware of significant transactions and changes in the business and seeks to discuss any tax issues arising at an early stage. When submitting tax computations and returns, Molson Group discloses all relevant facts and identifies any transactions or issues where it considers that there is potential for the tax treatment to be uncertain.
  • Molson Group makes the necessary corrections of material errors or misstatements in tax filings where permissible and/or required by law and practice without undue delay. Any inadvertent errors in submissions made to Tax Authorities are fully disclosed as soon as reasonably practicable after they are identified.

Date: 17 December, 2019