Tax Strategy Letter

Wessex Garages

ASE plc

Rowan Court Concord Business Park

Manchester M22 0RR

United Kingdom

0161 493 1930 

22 December 2017

Wessex Garage Holdings Ltd Penywell Road Bristol BS5 0TT

To the Board of Directors of Wessex Garage Holdings Ltd

Wessex Garage Holdings Ltd

On behalf of ASE Plc and ASE Audit LLP, I wish to confirm the following in support of the Wessex Garage Holdings Ltd Tax Strategy;

1. On behalf of ASE Plc I can confirm all of the tax and accounting professionals employed by ASE Plc who are currently engaged or who will be engaged on any matter concerning Wessex Garage Holdings Ltd have been given a copy of the Wessex Garage Holdings Ltd Tax Strategy which you have published

2. On behalf of ASE Audit LLP I can confirm that a copy of the Wessex Garage Holdings Ltd Tax Strategy which you have published has been incorporated within audit procedures which will ultimately form part of the opinion of the Statutory Audit opinion of Wessex Garage Holdings Ltd.

Accordingly, on behalf of ASE Plc and ASE Audit LLP, I confirm that we understand and will fully cooperate with Wessex Garage Holdings Ltd in the delivery of the objectives set out in the Wessex Garage Holdings Ltd Tax Strategy

Yours Sincerely

Michael Jones Chairperson

ASE Group Ltd

Wessex Garages Holdings Ltd Tax Strategy

The Wessex Garages Holdings Ltd Tax Strategy is composed of seven elements.

1. Tax Code of Conduct

The code of conduct applies to all tax professionals working on behalf of Wessex Garages Holdings Limited.

It endeavors to guide the role of tax professionals within the group, their key responsibilities, their professional conduct and their approach to working relationships with external parties.

Tax professionals must;

 Observe all applicable laws, rules, regulations and disclosure requirements.  Ensure all decisions are taken at an appropriate level, supported with documentation that evidences the facts, conclusions and risks involved.  Insist on certainty on tax positions adopted but where the tax law is unclear or subject to interpretation, written advice or confirmation must be sought in order to ensure that the view adopted would, more likely than not, be settled in favour of the advice received.  Develop and foster good working relationship with tax authorities, government bodies and other related third parties.  Act with due consideration is to be given to reputation, brand corporate and social responsibilities when considering tax initiatives as well as the applicable legal and fiduciary duties of directors and employees, all of which will form part of the overall decision-making and risk assessment process.  Be open, honest and transparent in all dealing with the tax and other relevant bodies.

Should any person have specific queries about this code of conduct, or would like advise on implementing it, they should speak with their line manager and if not adequately addressed, those queries should be brought to the attention of the Senior Accounting Officer, Mr Tim Bagnall

If confidential advice is required or there are concerns that cannot be addressed through line management please contact the Group Internal Control Manager, Mrs Sally Wilson

2. Tax risk management for interactions with business:

The business understands that the tax function should be involved throughout from planning to implementation in order to avoid failure in implementation, documentation or maintenance without corrective action.

The prominence of the commercial needs will under no circumstances override compliance with all applicable law. The tax function will therefore provide appropriate input.

As part of the approval process for business proposals to ensure a clear understanding of the tax consequences. The tax function will also then ensure accurate representation in tax returns and accounts.

3. Tax risk assessment procedures for decisions making:

Assessments will be made in the following circumstances;

 All business or share acquisitions and disposals.  All changes in corporate structure.  All significant business transactions.  All significant new processes affecting tax compliance.

A detailed assessment of risk will be carried out and which must be presented to the owner of the tax decision.

Risk assessment should include but not be limited to:

 A full description of the issue including a clear summary statement of the facts.  An assessment of the financial cost and benefits of all potential scenarios.  An assessment of the non-financial cost and benefits including an assessment of the nature and amount of resources to secure the benefit.  An assessment of the probability of the risk crystallising.  Commentary on the likely process of dispute resolution.  Recommendations.

Low-Risk issues are managed by the Head of Finance Department.

Medium-risk issues are managed by the Senior Accounting Officer, MrTim Bagnall, but subject to referral to external tax advisors for independent opinion.

High-risk issues are managed by the Board of Wessex Garages Holdings Ltd but subject to referral to external tax advisors for independent opinion.

4. Tax risk management in the compliance life cycle

The business will submit all retunes by their due dates in line with local tax law.

The tax function will monitor all changes in relevant tax law and practice and undertake regular training in order to asses any consequences for the group, with the minimum aim of mitigating any adverse impact.

The tax function will manage its compliance affairs to minimize the risk of any adverse public comment.

5. Tax authority relationships

The code of conduct requires the group to foster good relationships with tax authorities, governments and related third parties and to undertake all such dealings in a professional, courteous and timely manner.

6. Enquiry Management

Enquiries may include consideration of:

 The overall liability at stake including tax and penalties.  The degree to which consistency is relevant concerning one or more instances / events.  The likelihood of litigation.  The likely resource requirements and options to source enquiry compliance.  The reliance of expertise of information from third parties.  The risk of reputational damage.

At all times all members of the tax, function should seek to share knowledge and to seek input on all matters that could improve the management of task risk in order to resolve the enquiry expeditiously.

7. Artificial tax arrangements

The business will not engage in artificial tax arrangements.

The business acknowledges that the test of artificiality will be and is aligned with the existence or non-existence of a commercial purpose.