Literacy Capital plc publication of UK Tax Strategy

December 2024

Context

This document sets out the tax strategy for Literacy Capital plc (“Literacy Capital”) and applies for all UK entities in the group headed by Literacy Capital (“the Group”). It is set by the Finance Director who monitors the effectiveness and reviews the implementation of this policy.

We consider that our tax strategy is primarily of relevance to the Board of Directors and our Audit Committee. It is also of relevance to all finance, legal and operational personnel at Literacy Capital and the other companies in the Group whose decisions have tax consequences.

Literacy Capital is a closed-end investment company1 focused on investing in and supporting UK businesses and helping their management teams to achieve long-term success. The Group is made up of separate investment portfolio groups (“Portfolio Groups”) which are connected via Literacy Capital’s holding. Literacy Capital is also proud to have a charitable mission helping disadvantaged children in the UK learn to read, giving them a fair chance in life.

Literacy Capital is unique in that we are the only investment fund of our type to have been set up with a charitable objective. Our tax strategy reflects our commitment to corporate responsibility, ensuring that we pay our fair share of taxes and that we act with honesty and integrity.

How we manage UK tax risks

Literacy Capital’s investment strategy means that our portfolio investment companies are able to operate with sufficient autonomy to help them achieve their business objectives. Literacy Capital assists our portfolio investment companies with assessing and managing tax risks as they arise and addressing them in a timely manner in order to minimise exposure to tax risk. In doing so we ensure that our tax approach is applied consistently across the Group.

We do not have an internal tax function. As such, our tax matters (both centrally and in our portfolio investment companies) are prepared and reviewed by qualified tax professionals, closely following the appropriate legislation and relevant guidance.

With the help of our external tax and legal advisors we continually assess changes to the relevant tax legislation and ensure our tax practices comply with any updates to ensure we are proactive in mitigating tax risk.

To help ensure accountability and accuracy in our reports, each Portfolio Group has their own Senior Accounting Officer2 who has a detailed understanding of each company’s tax accounting and maintains oversight of the accounting controls and activities within their Portfolio Group. They are responsible for ensuring that the Portfolio Group complies with the relevant legislation and that all of their tax liabilities are calculated accurately and submitted to HMRC in a timely manner.

Our attitude to tax planning

The Group aims to operate in a manner that is tax efficient through claiming appropriate tax exemptions, reliefs and incentives, as they are intended to be used by the legislation. We make every effort to ensure we only engage in reasonable tax planning efforts, which support our commercial objectives and ethical standards.

We do not engage in any abusive or aggressive tax planning arrangements or enter into any schemes or transactions that are intended for tax avoidance. The Group does not enter into arrangements that will result in a different tax position than that intended by legislation. We do not tolerate or facilitate any activity that could be considered tax evasion.

All intra-group transactions are required to be priced on an arm’s length basis in accordance with internationally accepted transfer pricing standards and local tax laws.

Accepted Level of Risk

We operate with a limited appetite for tax risk due to the strong link between our tax strategy and our commitment to corporate responsibility. We do not make tax decisions or enter into arrangements that would facilitate a risk of producing a tax result that contravenes the spirit of the legislation.

We have a responsibility to our shareholders and employees to ensure that we do not incur unnecessary tax liabilities which could damage our business. We therefore take steps to ensure that we pay the correct amount of tax as intended by the relevant guidance and legislation.

Working with HMRC

Literacy Capital and the Group have a transparent relationship with HMRC. We are committed to building and maintaining a constructive relationship.

All queries or further information requests from HMRC will be dealt with in a timely manner so as to facilitate the fast resolution of any discrepancies and maintain a professional standing with HMRC.

We regard this document as complying with our duty to publish a UK group tax strategy for the year ending 31 December 2024 in accordance with Schedule 19, paragraphs 16(2) FA2016. Members of the Group covered by this tax strategy are those entities in which Literacy Capital has a direct or indirect holding of over 50% of ordinary share capital. In this strategy, references to “the Group”, “Portfolio Group” and “we” are to all these entities.

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1Literacy Capital is also an Investment Trust as defined by s1158 CTA 2010.

2 For companies joining the Group in the future, the Senior Accounting Officer will be appointed in line with the statutory time limits.