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Tax Strategy

Burberry’s Group Tax Strategy

As a global luxury retailer, wholesaler and manufacturer, operating in over 400 retail locations worldwide, we take our environmental, social and corporate governance responsibilities very seriously. Our tax strategy enables the Group to fulfil those responsibilities in respect of all applicable business taxes.

The tax strategy covers our approach in the following areas:

  • Governance, risk management and compliance
  • Tax planning
  • Dealings with Tax Authorities
  • Tax risk management

The tax strategy applies to Burberry Group plc, its worldwide subsidiaries and all officers, employees and third parties whose actions impact the management of Burberry’s tax affairs. It should be read conjunction with Burberry’s Code of Conduct, which outlines the key policies, processes and behaviours we expect our colleagues and partners to adhere to, while following all local laws and regulations.

Governance, risk management and compliance

Our Chief Financial Officer is responsible for the Group Tax strategy, the effectiveness of tax risk management, tax processes and transparency of reporting disclosures. The strategy is implemented by the global tax and trade compliance teams with the assistance of the finance leadership team. Compliance with the principles set out in the strategy is reviewed on an ongoing basis as part of the regular financial planning cycle. The Audit Committee is responsible for reviewing the Group Tax strategy at least once a year and significant tax matters as they arise.

Audit Committee meetings are attended by Group officers and employees including the Chief Financial Officer; Chief Executive Officer; Senior Vice President, Group and Corporate Finance; Senior Vice President, Internal Audit and Risk; Vice President, Group Financial Controller; Company Secretary and the General Counsel, who chairs the Ethics Committee and oversees all corporate responsibility matters.

Burberry is subject to tax in many countries. The Group employs an in-house team of qualified tax and trade compliance professionals who partner with the business and finance teams to manage the Group’s tax risks in a controlled and proactive manner. All staff in the relevant teams have the necessary training to manage our tax position appropriately.

We have established and maintain appropriate tax accounting policies and compliance processes to ensure the integrity of our tax returns and timely and accurate tax payments in all countries in which we operate. Corporate income tax compliance is mainly outsourced to third-party service providers, whose performance is monitored and regularly assessed against key delivery targets.

Tax planning

The Group is committed to acting with integrity and transparency on all tax matters and complying fully with all applicable tax laws, having regard to international standards and guidance on tax practice and tax reporting.

The Group will only engage in responsible tax planning aligned with genuine commercial economic activities. We do not use tax structures or undertake artificial transactions, the sole purpose of which is to create a contrived tax result. For example, we do not participate in transactions with parties based in tax haven jurisdictions when the transactions are not in the ordinary course of Group trading business, or which could be perceived as artificially transferring value to low tax jurisdictions.

Dealings with HMRC and other Tax Authorities

Burberry seeks to engage in open and constructive dialogue with HMRC in the UK and with tax authorities in all the territories in which we operate.

We strive to ensure that all tax filings are accurate and submitted on a timely basis. If we discover any inadvertent errors in tax returns or correspondence with tax authorities, we disclose them promptly. In the UK, the Vice President, Tax and the global tax and trade compliance teams have regular communication with our HMRC Customer Compliance Manager and specialist HMRC teams to promote a professional, collaborative working relationship.

We take an active role in contributing to the UK and international tax policy-making process, where relevant, including taking part in formal and informal consultations, either on our own account or through relevant trade and industry organisations.

Tax risk management

Burberry has a low tolerance for tax risk and proactively engages with advisors to achieve certainty on our tax position. The Group’s processes, policies and governance are designed to identify and mitigate material tax risks. The complex and ever-changing international tax environment, national regulatory developments and changes in the way we do business mean that there is always an element of tax risk and uncertainty inherent in the Group’s operations. To this end, we have formalised our tax risk identification, measurement, monitoring and reporting processes to manage these risks and ensure appropriate mitigation steps are taken. Significant tax risks and progress on mitigating actions are reported regularly to the Audit Committee.

In common with many other multinational groups, our most significant source of uncertainty arises where two or more governments adopt different interpretations in relation to transfer pricing arrangements and the tax treatment of intragroup, cross border transactions. Our Transfer Pricing policy has been developed in line with OECD guidelines on application of the arm’s length principles and domestic laws. Our approach provides an appropriate return to each entity in the Group, commensurate with the economic activity, assets and business risk assumed by that entity. While we operate a consistent global model for transfer pricing of goods and services, governments may adopt different and sometimes contradictory positions in relation to the same transaction or arrangement. We aim to seek assurance and resolution of any disputed transaction or arrangement through appropriate domestic or international dispute resolution procedures. Where appropriate we would seek assurance through advance pricing agreements.

This tax strategy1 was approved by the Audit Committee on behalf of the Board of Directors of Burberry Group plc on 19 March 2024 and covers the financial year from 31 March 2024 to 29 March 2025.

1This strategy complies with the UK legislative requirement in paragraph 16(2), Schedule 19 of the Finance Act 2016.

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