Tax policy

Introduction

This document sets out the tax strategy of Zenith Automotive Holdings Limited and its subsidiaries (‘Zenith’) for the year ended 31 March 2026. The publication of this strategy is regarded as satisfying the requirements of the Finance Act 2016, Schedule 19, Paragraph 16(2) for all UK operations and will remain in effect until it is superseded. This tax strategy was approved by the Board of Directors on 10th February 2026.

Approach to tax

Zenith is committed to conducting business with integrity, fairness and transparency.

We are committed to paying the right amount of tax at the right time, complying with all applicable tax laws, as a clear indication of our being responsible participants in society.

The business operates frameworks and embeds policies and procedures with the principal aim of achieving best practice, delivering good outcomes, and compliance with applicable laws and regulations. We combine these policies and procedures with appropriate technical and organisational measures to regularly assess risks and mitigate those risks. Our approach to tax is underpinned by these overarching principles.

Tax risk management and governance

Responsibility for implementing the tax strategy and management of tax-related matters lies with the Chief Financial Officer (‘CFO’), who is also the Group’s Senior Accounting Officer and member of the Holding Board.

The CFO and Group Finance Director (‘GFD’), with the support of the Senior Group Tax Manager and wider finance team, ensure adequate controls are in place to meet the Zenith’s tax obligations. The teams consist of appropriately qualified, experienced and professional individuals. Where appropriate, expertise is sought from external advisors to supplement internal capabilities, particularly for complex or uncertain tax matters.

The business recognises that tax is an inherent element of many commercial transactions, thus the CFO and GFD are involved in the decision-making process of material transactions and provide appropriate input into the business proposals to ensure a clear understanding of the tax consequences of any decisions made.

In addition, on a monthly basis the CFO and GFD attend the Enterprise Risk committee. All members of this committee are members of Zenith’s Executive Committee. Significant tax risks and developments are considered by this committee to ensure that decisions are made in accordance with this tax strategy.

Zenith seeks to manage the level of tax risk as far as practically possible. Our appetite for tax risk is low. We utilise a tax risk register to document identified tax risks and the controls in place to address each risk. These risks and controls are reviewed regularly to ensure that the register is complete, and there is a continuous programme of testing to validate that these controls are operating effectively. Changes are made to processes and controls when required to reflect business and legislative changes.

The Senior Group Tax Manager engages with the wider business regularly on tax to provide advice on the operational impact of tax matters, to ensure that tax strategy, policy and messages are cascaded across the business and that significant tax matters are escalated appropriately to provide both downstream and upstream tax dialogue. Regular dialogue with the wider business is a key tool for managing and minimising tax risk.

Attitude to tax planning

Zenith will not undertake tax planning that is contrived or artificial, where the sole purpose is to reduce its tax liability. We aim to do this by ensuring that we report our tax affairs in ways that reflect the economic reality of the transactions we undertake in the course of our trade. When conducting our day-to-day operations, the business will take advantage of available tax incentives, reliefs and exemptions, seeking advice from external advisors where uncertainty or complexity exist. Zenith does not have a target effective tax rate.

Working with HMRC

Zenith is committed to the principles of openness, transparency and honesty when managing its tax affairs and when working with HMRC. We achieve this by seeking the views of HMRC on uncertain tax positions as they arise, and by responding fully and timely to HMRC correspondence.