Tax Strategy - December 2023

Introduction

This statement is prepared in accordance with the requirements of paragraph 17(4), schedule 19 of the Finance Act 2016 in relation to the financial year ended 31 December 2023. This document sets out the Williams Group policy and approach to conducting its tax affairs including dealing with tax risk. The document is effective from year ending 31 December 2016 and is reviewed annually by the Director of Finance, with any amendments requiring approval by the Board of Directors.

The overall Group objective is to ensure that the correct amount of tax is paid at the right time, whilst maintaining an open and professional relationship with HMRC. The Group remains compliant with UK legislat ion and does not engage in any form of abusive or aggressive tax planning, but does maximise any legitimate tax reliefs allowed within tax legislation e.g., capital allowances. The Group is fully committed to the prevention of the facilitation of tax evasion and has a nontolerance policy with respect to tax fraud.

References to tax include all forms of direct and indirect UK tax including corporation tax, VAT, employment

taxes, stamp duty and land taxes (SOLT).

Governance

The Group is committed to ensuring its tax governance is adopted and followed consistently, with clear lines of responsibility and accountability, whilst responsibility for its tax strategy remains with the board of Directors.

Relationships with tax authorities

HMRC has sought to address the relationship between large businesses and itself, and promote best practice in business governance over its tax affairs. The Williams Group therefore adopts an open and transparent approach when dealing with tax aut horities working collaboratively in a professional, courteous and timely manner.

The Group aims to:

  • Engage in full, open and early dialogue with HMRC to discuss tax matters.
  • Observe all applicable laws, rules, regulations and disclosure requirements.
  • Be compliant with all anti-bribery legislation.
  • Make accurate and timely disclosures in correspondence and returns, and respond to queries and information requests promptly.
  • Apply diligence and care in the management of risks associated with tax matters and ensuring governance procedures are appropriate.

  • In 2022 HMRC confirmed that the Group is classified as "Low Risk" due to its approach to governance and compliance. It is the Group's objective to maintain this classification.

    Tax risk management

    The Group is committed to observing all applicable laws, rules, regulations, reporting and disclosure requirements, whilst mitigating any inherent risk through robust and well-established operating policies and procedures. This encompasses established processes and controls at both local and group level to ensure items are accounted for consistently and accurately, whilst in depth reviews are carried out in areas of perceived risk to identify non-compliance. These controls form the basis on which the Senior Accounting Officer (SAO) certificate is signed annually.

    The Groups VAT returns are submitted via bridging software approved by HMRC and are compliant with the Making Tax Digital requirements in this area.

    The Group also utilises an industry standard dealer management system (DMS) for all its operational and tax accounting requirements, including a hosted payroll function, ensuring that all direct and indirect taxes are calculated and collected accurat ely. This externally sourced OMS provides HMRC the reassurance that the system is robust and can be interrogated independently, it also ensures that changes to legislation are correctly applied and reflected in tax returns.

    Tax planning

    The Williams Group trades in a tax efficient manner whilst remaining compliant with all applicable laws, it engages a third-party auditing firm (RSM UK) to provide expert advice and guidance in relation to all tax matters, including the calculation and submission of the Group corporation tax liability.


    Guy Adams, MD's Signature

    Guy Adams

    Managing Director

    This statement was updated and approved on 14 December 2023.


    Modern Slavery and Human Trafficking Statement

    The Williams Group of companies are fully committed to understanding all modern slavery risks and ensuring that there is no modern slavery in their own businesses or its supply chains. 

    Purpose 

    The Modern Slavery Act 2015 requires businesses whose sales are in excess of £36 million to publish their efforts to eradicate slavery and human trafficking. This statement explains the steps taken during the financial year to ensure slavery and human trafficking does not occur in any part of our business or supply chain. 

    Our Anti-Slavery and Human Trafficking Policy 

    Modern slavery is a crime and a violation of human rights. It takes various forms, including slavery, where ownership is exercised over a person, servitude which involves the obligation to provide service imposed by coercion, forced or compulsory labour, involves work or service exacted from a person under menace of a penalty, and human trafficking which comprises arranging or facilitating the travel of another with a view to exploiting them. 

    We are committed to acting ethically and with integrity in all our business relationships, whilst ensuring that there is no modern slavery or human trafficking in our supply chains or any part of our business. 

    Our business and supply chains 

    The Williams Group is one of the leading motor retail groups in the Northwest of England representing the BMW, MINI, Jaguar and Land Rover brands and employs approximately 850 people. The Group specialises in the retailing of new and used vehicles including provision of finance and insurance products, service and repair including parts and a head office support function. 

    Our supply chains are predominately the major international motor manufacturers supplying vehicles and aftersales parts, whose supply chain in turn is complex and includes overseas elements. The complex nature of the manufacturers supply makes it extremely difficult for the Group to manage any issues in their supply chain and is ultimately the responsibility of the manufacturer. 

    Due Diligence -Slavery and Human Trafficking 

    The Williams Group takes a risk-based approach in assessing our exposure to slavery and human trafficking within our supply chains. Our aim is to ensure that our own high standards for ethical conduct are shared by each supplier with which we do business from the outset of the procurement process. 

    We are committed to reviewing our existing supply chain to ensure where a potential risk is identified we engage with the supplier to establish whether they have implemented their own arrangements with prohibitions against modern slavery and human trafficking. 

    We carefully select new suppliers undertaking relevant due diligence to enable us to assess their processes and procedures in relation to modern slavery and human trafficking in their own organisation and supply chain. 
    Training and awareness 
    We will be providing awareness training to senior management to allow them to ensure they are able to identify the risks of modern slavery and human trafficking in our supply chains and our business. 
    The Williams Group has a zero-tolerance approach to modern slavery and human trafficking and has not been able to identify any suggestions that it applies to any of our supply chain. 

    Guy Adams, MD's Signature

    Guy Adams

    Managing Director

    This statement was updated and approved by the Board of Directors on 14 December 2023.


    Complaints Procedure

    Our commitment to you

    At Williams’s motor company our aim is to always provide outstanding customer service. As a customer, if you feel that our service has not met your expectations then we will endeavour to resolve your concerns as quickly as possible. We define a complaint as; any expression of dissatisfaction, whether oral or written and whether justified or not. Your complaint will be taken seriously, and we will make every effort to resolve the problem as quickly as possible. However, this might not always be possible and a complaint might require a more detailed investigation.

    To make a complaint direct to Williams Motor Company.

    In the first instance please fully complete the form using the link below indicating which of the Williams Motor Company locations that your complaint relates to. We will acknowledge receipt of complaint within 72 hours. Our priority will be to resolve any complaints within a timely manner, however, this might not always be possible and a complaint might require a more detailed investigation.

    If we cannot resolve your complaint within 8 weeks, you may refer your dispute to the Financial Ombudsman Service. This service is free to use. Their consumer helpline is available on 0800 023 4567 or 0300 123 9123 or you can visit their website at www.financial-ombudsman.org.uk

    MAKE A COMPLAINT


    If you have a complaint about the sale of a regulated Insurance or finance products

    You can notify Automotive Compliance Ltd of your Regulated complaint through the following channels;

    In writing:

    The Factory, 44 Alfred Street, Gloucester, GL1 4DD.

    Telephone: 01452 671560

    E-mail: complaints@automotive-compliance.co.uk

    Statement of Investment Principles

    This Statement of Investment Principles ("the Statement") has been prepared by the Trustees of the Williams Motor Co. (Holdings) Limited Retirement Benefits Plan ("the Plan") in accordance with Section 35 of the Pensions Act 1995, as amended, and its attendant Regulations.

    The Statement outlines the principles governing the investment policy of the Plan and the activities undertaken by the Trustees to ensure the effective implementation of these principles.

    In preparing the Statement, the Trustees have:

  • Obtained and considered written advice from a suitably qualified individual, employed by their investment consultants, Mercer, whom they believe to have a degree of knowledge and experience that is appropriate for the management of their investments; and
  • Consulted with the Sponsoring Employer, although they affirm that no aspect of their strategy is restricted by any requirement to obtain the consent of the Sponsoring Employer.



    The advice and the consultation process considered the suitability of the Trustees' investment policy for the Plan.



    The Trustees will review the Statement formally at least every three years to coincide with the triennial Actuarial Valuation or other actuarial advice relating to the statutory funding requirements. Furthermore, the Trustees will review the Statement without delay after any significant change in investment policy. Any changes made to the Statement will be based on written advice from a suitably qualified individual and will follow consultation wrth the Sponsoring Employer.



    The Plan operates both defined benefit ("DB") and defined contribution ("DC") sections. It is a hybrid arrangement; some members are subject to a defined benefit underpin ("underpin members"), namely GMP in respect of service before 6 April 1997, and some members have DC only benefits ("DC members"). A small number of underpin members may require a top-up to their defined contribution fund at retirement from the Plan's unallocated funds for the defined benefit underpin to be provided.


  • Click below to read the full document:

    Statement of Investment Principles




    Annual Implementation Statement

    This statement sets out how, and the extent to which, the Statement of Investment Principles (‘SIP’) produced by the Trustees have been followed during the year to 30 June 2021. This statement has been produced in accordance with The Occupational Pension Schemes (Investment and Disclosure) (Amendment and Modification) Regulations 2019 and the guidance published by the Pensions Regulator.

    This Implementation Statement covers both the Defined Benefit (“DB”) and Defined Contribution (“DC”) Sections of the Plan.

    The table later in the document sets out the how, and the extent to which, the policies in the SIP have been followed

    Investment Objectives of the Plan
    The Trustees believe it is important to consider the policies in place in the context of the investment objectives they have set. The objectives of the Plan with respect to the DB and DC Sections included in the SIP are as follows:

    DB Section
    -To achieve an overall rate of return that is sufficient to ensure that assets are available to meet all liabilities as and when they fall due. In doing so, the Trustees also aim to maximise returns at an acceptable level of risk taking into consideration the circumstances of the Plan.

    DC Section
    -
    To provide suitable investment options that are aligned to the needs of their members that will optimise the return on investments in order to build up a savings pot which will be used in retirement
    - To provide members with an appropriate range of investment funds and a suitable default strategy.

    Click below to read full statement.

    ANNUAL IMPLEMENTATION STATEMENT


    Chair Statement

    Click below to view our Williams Chair's Statement:

    WILLIAMS CHAIR STATEMENT