This tax strategy applies to all taxes applicable to The&Partnership Group and the document will be reviewed annually, updated as appropriate and approved by the Chief Financial Officer (CFO), on behalf of the Board. The CFO is accountable to the Risk Committee and the Board for the implementation of the tax strategy and the management of tax and related risk. This tax strategy applies to all The&Partnership Group companies and to our dealings with our clients.

Governance and risk management

The Group is committed to the delivery of the tax strategy, and this will be owned by the Group's CFO who is ultimately accountable for Tax, and who is also the Group's Senior Accounting Officer.

The CFO has responsibility over The&Partnership's approach to tax on day-to-day basis which includes the identification, prioritisation and monitoring of tax risk across the business, as well as the escalation of tax risk to the Board and the Risk Committee. The ongoing monitoring of tax accounting arrangements as part of annual SAO compliance provides part of this process.

Management of tax risk

As a large multi-national group with operations globally, the Group is exposed to a variety of tax risks. These can be grouped under the following headings:

1. Tax compliance and reporting risks, which cover risks associated with compliance failures such as submission of late or inaccurate returns, the failure to submit claims and elections on time or where finance or operational systems and processes are not sufficiently robust to support tax compliance and reporting requirements.
2. Transactional risks, which arise where transactions are carried out or actions are taken without appropriate consideration of the potential tax consequences or where advice taken is not correctly implemented.
3. Reputational risks, which looks beyond financial risks to the wider impact tax risk may have on our relationships with our stakeholders, including shareholders, clients, and the tax authorities.

The&Partnership works closely with WPP, our biggest shareholder, who have a team of tax professionals based predominantly in London and New York. Along with our external tax advisors, they provide advice on tax-related issues, undertake or assist with tax filings, manage relationships with tax authorities and assist with various forms of tax and financial reporting.

Where appropriate, we also engage with tax authorities to disclose and resolve issues, risks and uncertain tax positions. The subjective nature of many tax rules does however mean that it is often impossible to mitigate all known tax risk. Indeed, in certain situations, an element of tax risk may be maintained, where we believe our approach is consistent with the principles set out in our tax strategy and where the range of potential outcomes is in accordance with our risk parameters. Thus, at any given time, the Group may be exposed to some risk arising from its tax affairs, although we aim to manage and mitigate tax risk wherever possible.

Tax compliance and reporting

We are committed to meeting all our legal and regulatory requirements in paying the correct amount of tax and meeting our tax compliance obligations. For example, in the UK, as part of this commitment, we comply with the Senior Accounting Officer (SAO") requirements and we undertake a review of our tax processes (for Corporation Tax, VAT and Employment Taxes) as part of this process.

We seek to apply diligent professional care and judgement in our tax compliance activities, and provide sufficient evidence to support all judgements made.

Relationships with Tax Authorities

The Group is committed to working collaboratively with tax authorities, through open and transparent dialogue to ensure it is compliant with all of its compliance and filing obligations.

Wherever possible, we also seek to achieve early agreement on issues and certainty wherever possible.

Our approach to tax planning

We take a low-risk approach to tax planning, and tax decisions are aligned to business and commercial strategy. Like any other business expense however, we seek to create value for our partners. As such, we may respond to tax incentives and exemptions where appropriate and in a way that is consistent with tax authority and government policy.

As appropriate, we will seek external professional tax advice to ensure we apply these incentives and exemptions legitimately, and if appropriate, we seek advance clearances from the appropriate tax authority to ensure we minimise the risk of uncertainty.

Level of risk in relation to UK taxation that the Group is prepared to accept Where tax law is unclear or subject to interpretation, we take external tax advice and any adopted tax position is at least probable to apply.

Transparency

We support initiatives to improve international transparency on taxation matters, including OECD measures on country-by-country reporting and automatic exchange of information.

We do not tolerate tax evasion, nor do we tolerate the facilitation of tax evasion by any person(s) acting on our behalf.

This Tax Strategy document

This document meets the requirement for The & Partnership to publish its Tax Strategy as required by paragraph 19 of Schedule 19 of the Finance Act 2016. It is effective and applies for our year ended 31 December 2023 financial year and was updated and approved by the Board in August 2023 and published in the same month.