Group Tax Strategy
STEER AUTOMOTIVE GROUP TAX STRATEGY
Financial year ended 31 March 2026 The document comprises the Tax Strategy of Steer Automotive Group and its constituent companies. The Board undertook a review of the Group’s Tax Strategy prior to its publication and confirmed that it was appropriate.
Introduction
The following sets out the Tax Strategy adopted by all members of the Steer Automotive Group in dealing with their tax affairs for the year ended 31 March 2026. It has been prepared and published by Belfry Topco Limited, the head of the Steer Automotive Group, in accordance with paragraph 16(2) Schedule 19 of the Finance Act 2016.
This Strategy is reviewed and refreshed annually and covers all UK taxes as set out in the Appendix.
Governance and Risk Management
The Board sets out the overall strategy of the Group in relation to taxation, with overall responsibility for oversight of the tax affairs of the Group delegated to the Chief Financial Officer. The Chief Financial Officer is also the Senior Accounting Officer (“SAO”) for all Group companies.
The day-to-day management of the Group’s tax affairs is dealt with centrally with responsibility for this delegated to the Group UK Taxation Manager. In addition, the Group uses a panel of appropriately qualified external advisors to provide additional tax support and advice where the Group does not have appropriate in-house expertise or resource, or where the position is complex.
The Chief Financial Officer meets with the Group Head of Financial Control, the Group Mergers and Acquisitions Director, the Group’s UK Taxation Manager and other senior managers to review the tax risk and control processes within the Group, as well as to discuss all other aspects of taxation. Furthermore, the Board receives regular updates of the tax position of the Group, including a summary of all HM Revenue and Customs (“HMRC”) activity in relation to the Group, and will, discuss taxation at other meetings periodically throughout the year.
Tax cash flow management
The Group will ensure that it meets its obligation to pay the “right amount of tax at the right time”. The “right amount of tax” is the correct amount of tax legally due in any territory, in accordance with the legislation enacted by its government.
Tax risk
Strategies and procedures to control and manage tax risk will be adopted, thereby minimising the risk that tax positions are misstated to the tax authorities. The Group has a low appetite for tax risk. The Group also seeks to obtain certainty on any transactional risk, particularly in relation to complex transactions such as business acquisitions. As a result, where after taking appropriate external advice, if the position is not free from doubt, it is discussed with HMRC or overseas tax authority at an early stage with a view to seeking clarity on the tax position.
Tax planning arrangements
Whilst the Group has a responsibility to its shareholders to deliver value, it also recognises its broader, social responsibilities to pay the right amount of tax at the right time.
The commercial needs of the Group are paramount and all tax planning will be undertaken in this context.
As such, the Group will specifically not enter transactions that serve no commercial purposes other than reducing the tax liabilities of the Group.
However, where commercial transactions are being entered into, the Group will take advantage of any reliefs and exemptions, as set out in legislation, to minimise its tax liabilities.
Disclosure
Compliance with all relevant disclosure and tax authority approval requirements will be adopted by the Group.
The Group aims for certainty on the tax positions that it adopts.
Where tax law is unclear or subject to interpretation, the treatment of an item will be based on the “more likely than not” standard, such that the item will be settled in our favour if it is enquired into.
Where the tax treatment of an item is so uncertain and/or unquantifiable such that the “more likely than not” assessment is not possible, robust risk assessment and documentation will take place to support the full disclosure made to the tax authorities.
Effective tax rate
The Group does not have a target effective tax rate applicable to its corporate income and deferred tax positions as recorded in its financial statements. All of the profits of the Group are subject to full UK or overseas country corporation tax which, together with the recognition criteria for tax in the applicable accounting standards, drives the effective rate of tax reported by the Group.
Tax authority relationships
We will develop and foster good working relationships with tax authorities, government bodies and other related parties. Openness, honesty and transparency will be paramount in dealings with tax authorities and other relevant bodies.
The Group is in regular contact with HMRC, the UK tax authority across all applicable taxes, regarding developments in the business, interpretation of legislation and guidance, and in relation to existing or future tax risks.
The Chief Financial Officer, Group Head of Financial Control and the Group’s UK Taxation Manager will meet formally with the HMRC Customer Compliance Manager (“CCM”) on an annual basis upon HMRC’s awaited appointment of a CCM to the Group.
Tax disputes
Tax disputes, to the extent that they arise, will be pro-actively managed.
We will undertake all dealings with tax authorities in a professional, courteous and timely manner.
Signed Darren Mee Chief Financial Officer
30 March 2026
Appendix
The UK taxes covered by this Group Tax Strategy, in accordance with paragraph 15(1) Schedule 19 of the Finance Act 2016, are:
• income tax,
• corporation tax (including any amount assessable or chargeable as if it were corporation tax or treated as if it were corporation tax),
• value added tax,
• amounts for which the companies are accountable under PAYE regulations,
• diverted profits tax,
• insurance premium tax,
• annual tax on enveloped dwellings,
• stamp duty land tax,
• stamp duty reserve tax,
• petroleum revenue tax,
• customs duties,
• excise duties, and
• national insurance contributions.
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