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The Adaptavist Group tax strategy

For the financial year ended 30 September 2025

1. Introduction

This document sets out the UK tax strategy of the Adaptavist Group (the “Group”) in accordance with the requirements of Schedule 19 of the Finance Act 2016. This strategy applies to all UK taxes and all UK companies within the Group¹.
The Group is committed to conducting its tax affairs in a responsible manner, ensuring compliance with all relevant tax laws and regulations, and maintaining an open and constructive relationship with HM Revenue & Customs (“HMRC”).
This tax strategy is reviewed and approved annually by the Board and applies for the financial year ended 30 September 2025.

2. Approach to risk management and governance arrangements

The Group acknowledges that managing tax risk is an integral part of its overall risk management framework. The objective is to ensure that tax risks are identified, evaluated and managed appropriately, with a focus on compliance with tax legislation.
Overall responsibility for the Group’s tax strategy and its implementation rests with the Chief Financial Officer (CFO), The Board provides oversight of tax matters as part of broader governance responsibilities and maintains an appropriate level of involvement in reviewing significant tax risks and approving the Group’s tax strategy.
The Adaptavist Group hire suitably qualified and experienced people in key positions for managing tax risks and governance, ensuring that appropriate processes and controls are in place to manage tax compliance and reporting obligations. Where appropriate, the Group uses external tax advisors to provide specialist input on areas of uncertainty or when tax legislation is subject to interpretation.

3. Attitude towards tax planning

The Group adopts a responsible approach to tax planning and does not engage in artificial or aggressive tax arrangements that are designed primarily to achieve tax advantages without underlying commercial substance.
Tax planning is undertaken only where it supports genuine commercial activity and aligns with the Group’s business objectives. The Group actively engages with external tax advisers to ensure it remains compliant with applicable tax legislation and to take into account relevant tax considerations when planning activities or transactions.

4. The approach towards dealings with HMRC

The Group is committed to maintaining an open, transparent and professional relationship with HMRC.
The Group seeks to engage proactively with HMRC where appropriate and aims to respond to queries in a timely and cooperative manner. In making tax decisions, the Group considers HMRC-published guidance, alongside applicable legislation and professional advice.
The Group aims to ensure that all tax filings are accurate, complete and submitted within statutory deadlines.

5. Level of risk in relation to UK taxation

The Group adopts a low-risk approach to UK taxation, seeking to minimise uncertainty and avoid disputes with HMRC wherever possible. Where uncertainty exists, the Group will seek appropriate advice and, where necessary, engage with HMRC to agree the correct tax treatment.
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¹ UK companies within the Adaptavist Group covered in this policy:
  • Adaptavist Group Ltd
  • Adaptavist UK Services Ltd
  • Adaptavist Travel Limited
  • Adaptavist Holdings Limited
  • ARUK Global Limited
  • Adaptavist Ventures Limited
  • Kolekti Limited
  • AVSTC Limited
  • Salable Limited
  • Clever Consultants Limited (Brew)