1. Background
The Tax Strategy of Trainline PLC (“Trainline”, the “Company” or the “Group”) is guided by our purpose to make rail and coach travel easier and more accessible, thereby encouraging people to make more environmentally sustainable travel choices and our commitment to be a responsible and sustainable business. Our values reflect: our commitment to our people; our customers; to innovation and integrity; and being the best at what we do.
This document sets out the Tax Strategy of Trainline plc and its subsidiary undertakings (hereinafter, collectively referred to as ‘the Group’). The Tax Strategy will be periodically reviewed, and any material amendments will be approved by the Board of Trainline plc. The Tax Strategy applies to all forms of taxes payable by the Group, including direct taxes, indirect taxes, payroll-based taxes, etc. This document sets out the Group’s tax risk management policy, which covers both the internal governance of tax matters and the approach to tax.
2. The Group’s approach to tax risk management and governance arrangements in relation to taxation
Responsibility for the Group’s approach to tax and the management of tax risk sits with the Board of Directors. We operate a standard RACI methodology to allocate ownership for different-tax related activities, such as payroll, corporate taxes, and different taxes globally. We seek to ensure that we set a single quality standard for our tax compliance activities globally. Our central UK based Head of Tax monitors our tax control framework and reviews it regularly.
The day-to-day management of tax compliance of the Group sits with the Head of Tax, under the oversight of the Finance Director and ultimately the Chief Financial Officer. The finance teams of the Group are accountable to the Board in respect of the management of tax and related risk.
The business does not fix a monetary level of acceptable risk but seeks to minimise the risk of operational failure. The Group has developed systems, controls, policies, and procedures to identify and manage tax risk. Specifically, in relation to UK tax, the risks inherent in the calculation, collection, and payment of taxes are mitigated by the controls in place.
The Group aims to achieve these objectives through:
- Submission of all tax returns on a timely basis, including providing sufficient detail to enable tax authorities to form an accurate view of the affairs of the company filing the return.
- Paying the appropriate amount of tax at the right time. Where this view may differ to the position taken by HMRC, the UK Group aims to be transparent about the filing position it has taken through relevant disclosures.
- Maintaining tax accounting arrangements which are robust and accurate to comply with the Senior Accounting Officer (SAO) provisions in the UK.
- Ensuring that the finance department, involved in the Group’s tax processes, is adequately resourced, and supported and that key personnel are retained to manage tax compliance issues on a timely basis; and
- Ensuring all tax filing positions are supported with appropriate documentary evidence.
3. The Group’s attitude to tax planning
In structuring our commercial activities, the Group does not engage in artificial transactions of which the sole purpose is to reduce tax. The Group may consider undertaking a transaction in a way that gives rise to tax efficiencies providing this is aligned to the Group’s commercial objectives and complies with the associated tax legislation. The Group does not engage in tax efficiencies if the underlying commercial objectives are not supported, or if the arrangements impact upon the Group’s reputation, brand, corporate and social responsibilities or future working relationships with tax authorities. External advice is sought in relation to areas of complexity or uncertainty to support the Group in complying with its tax strategy and obligations.
As the Group grows internationally, we will consider, amongst other factors, the tax laws of the countries in which we provide services. We allocate our profits through transfer pricing to the countries where they originate - for Trainline, primarily the UK and France. We apply OECD principles to transfer pricing, which mean our related entities trade with each other as if they were unrelated.
UK tax law and its interaction with international tax law remains complex and tax outcomes can sometimes be uncertain. Accordingly, the Group frequently seeks an opinion from external advisers to confirm its understanding of how complex tax law is likely to operate to ensure it is complying with both the letter and spirit of the tax law in the jurisdictions we operate.
4. Working with HMRC
The UK Group will comply with all relevant legal disclosure and approval requirements and all information will be clearly presented to HMRC. In its dealings with HMRC, the Group will act in an open, honest and transparent manner. The UK Group will maintain an open dialogue with HMRC on a real-time basis where possible to minimise tax risk. The Group’s aim is to avoid unnecessary disputes with HMRC and thus minimise tax risk, and we will look to achieve this through regular communications and where appropriate, seeking pre-transaction clearances from HMRC and making the tax compliance procedures and controls available for review by HMRC upon request.
This tax strategy is in accordance with the requirements set out under paragraph 16(2) of Schedule 19 of the Finance Act 2016 to publish the Group tax strategy. This tax strategy applies to the year ended 28 February 2024.
For more information concerning our Governance visit our Governance page.