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Highland Fuels Limited – Tax Strategy

Introduction

This tax strategy has been prepared and published in accordance with paragraph 16(2), Schedule 19,
Finance Act 2016 on behalf of Highland Fuels Limited and all entities in the Highland Fuels group of
companies (the ‘Group’). This tax Strategy is effective from 1 January 2025, this being the
commencement of the current financial year (which is ended 31 December 2025).


The tax strategy will be reviewed annually, updated as appropriate and approved by the Board of
Directors. The Group Finance Director (who is also the Senior Accounting Officer for reporting
purposes) is responsible for setting and monitoring the strategy; the finance team within the Group
are then responsible for implementing and managing the tax strategy and related risk.


The tax strategy is consistent with the strategy and operations of the Group and been approved by
the Board of Directors. It outlines the Group’s approach to:

  • Tax Risk Management
  • Attitude Towards Tax Planning
  • Tax Risk Appetite
  • Relationships with Tax Authorities


Tax Risk Management

The Group is committed to full compliance with all UK tax laws applicable to the business including,
but not limited to Corporation Tax, Employments Taxes, Value Added Tax, Excise Duties and Stamp
Duty.


The Group’s tax systems, processes and controls are long established, robust and are regularly
reviewed and updated where appropriate to keep pace with tax legislation. The finance team is
experienced in tax matters in their areas of responsibility and is headed up by the Finance Director
who has close involvement with the management accounting and tax reporting for the Group.
The Finance Director regularly updates the Board on tax matters and keeps it fully informed on any
significant changes which impact the business.


The routine tax affairs of the Group are generally administered internally but in cases where a
requirement for specialist tax advice is identified, the Group engages with external advisors for
appropriate advice to ensure compliance and mitigate any tax risks.


Attitude Towards Tax Planning


The Group only operates in the UK and has a straightforward approach to tax planning in that it
operates in a tax efficient manner, taking advantage of tax reliefs and allowances available to it in the
normal course of business.


The Group has a very low risk attitude to tax and therefore does not seek or participate in any
aggressive tax avoidance schemes or complex tax structuring.

Tax Risk Appetite


The Group has a low risk appetite to all tax related matters, and manages its tax affairs in a proactive
manner to ensure compliance with all relevant UK tax requirements/legislation.


As the Group only operates in the UK only, and due to the nature of the business, the following are
the main tax risk areas:

  • Failure to comply, such as late submission of returns or inaccurate returns.
    Undertaking transactions without appropriate consideration of potential taxation
  • consequences.
  • Incorrect implementation of advice taken.
  • Financial and operational systems and processes being insufficient to support tax compliance
    and reporting requirements.


The Group uses third party advisors to provide advice and guidance as necessary to assess tax risks
and ensure compliance with applicable legislation and disclosure requirements. The aim is to ensure
full compliance with all statutory obligations and as a consequence seek to minimise risk wherever
possible.


Relationship With HMRC


The Group has an open and transparent relationship with HMRC. Where appropriate, the Group
approaches HMRC for guidance in relevant matters at early stages and, conversely, provides any
information requested by HMRC in a concise and timely manner.

The tax strategy document of the Group is reviewed regularly, at least annually, with any revisions
published online when approved by the Board of Directors.


The policy has been updated since the last version published in June 2024, which is primarily so that
the tax strategy now reflects the Group’s risk appetite to tax.


Date of Publication: June 2025