WFL (UK) LTD Tax Strategy

Financial year ending 31 March 2027

This UK tax strategy (“The Strategy”) has been approved by the Board of Directors of WFL (UK) Ltd (“Watson Fuels”). The Strategy relates to the year ending 31 March 2027.
The Strategy sets out Watson Fuels' approach to managing UK taxation, including our approach to tax governance, tax risk management, tax planning and our relationship with HM Revenue and Customs (“HMRC”). It is published in accordance with paragraphs 19(2) and 22(2) of Schedule 19 Finance Act 2016 and applies to the Watson Fuels group companies listed in Appendix 1.
For the purposes of this Strategy, ‘UK Taxation’ includes the taxes and duties referred to in paragraph 15(1) of Schedule 19 to the Finance Act 2016. This includes, but is not limited to, corporation tax, VAT, PAYE, National Insurance contributions, stamp taxes, insurance premium tax and fuel duty.
As a fuel and lubricants distributor, Watson Fuels also recognises its responsibilities in relation to excise duty and its obligations as a Registered Dealer in Controlled Oil (“RDCO”), including compliance with Excise Notice 192 and any related HMRC guidance.

Watson Fuels is committed to complying with applicable UK tax laws, regulations and reporting obligations. We seek to manage our UK tax affairs in a responsible, transparent and controlled manner.
The Board of Directors has ultimate responsibility for this tax Strategy and for oversight of the Company’s approach to UK taxation. Day-to-day responsibility for tax compliance and tax risk management sits with the finance function, under the oversight of senior management.
Watson Fuels seeks to maintain appropriate processes and controls to identify, assess, manage and monitor UK tax risks. These include controls over accounting records, return preparation, review and approval processes, submission deadlines and payment obligations.
Where tax law is complex, uncertain or subject to interpretation, Watson Fuels seeks input from appropriately qualified external advisers. Tax matters are escalated to senior management and, where appropriate, to the Board

Watson Fuels undertakes tax planning only where it is aligned with genuine commercial and economic activity.
We do not enter into artificial tax arrangements or transactions whose main purpose is to secure a tax advantage that is contrary to the intention of UK tax legislation.
Where reliefs, exemptions or incentives are available under UK tax law, Watson Fuels may utilise them where doing so is consistent with the relevant legislation and its intended purpose.
Where there is material uncertainty in relation to a tax position, Watson Fuels will seek appropriate professional advice and, where relevant, engage with HMRC.

Watson Fuels has a low tolerance for UK tax compliance risk.
We seek to minimise the risk of errors, late filings, late payments, penalties, inaccurate returns or failures to meet our UK tax obligations. This is particularly important in relation to fuel duty, excise duty and RDCO compliance, given the nature of our business.
Watson Fuels recognises that a degree of tax risk may arise due to the complexity of UK tax legislation and HMRC guidance. Where uncertainty arises, we seek to manage that risk through internal review, appropriate controls, external professional advice and, where appropriate, engagement with HMRC.
Watson Fuels does not knowingly take tax positions that are artificial, aggressive or inconsistent with the commercial substance of its activities.

Watson Fuels seeks to maintain an open, transparent and constructive relationship with HMRC.
We aim to engage with HMRC in a timely and cooperative manner, particularly in areas of higher tax risk such as fuel duty, excise duty and RDCO compliance.
Where errors or uncertainties are identified, Watson Fuels seeks to address them promptly and responsibly. Where appropriate, this may include making voluntary disclosures to HMRC.
Watson Fuels aims to respond to HMRC enquiries accurately, fully and within agreed timescales, and to resolve any issues in a constructive manner.