This document sets out the tax strategy of Vision Express Limited and its UK subsidiary undertakings (“Vision Express”), and in making this strategy available Vision Express is fulfilling its responsibilities under Schedule 19 of the Finance Act 2016.

The Vision Express tax strategy is guided by our wider Corporate Social Responsibility agenda. Our stated values reflect our commitment to Taking Vision Seriously and to being a responsible and caring retailer. We see responsible administration and payment of tax as a responsibility of our business.

Our overall tax strategy is to:

We are a wholly owned subsidiary of GrandVision N.V. based in the Netherlands, and adhere to the principles and philosophy of that company. As regards tax, this is explained further in the following link: https://www.grandvision.com/sustainability/csr-focus-areas/focus-area-2/by-pursuing-a-transparent-and-responsible-tax-strategy.htm

Vision Express Limited and all of its subsidiary companies are UK registered companies and subject to tax in the UK, other than the Irish subsidiary companies operating the Irish Vision Express stores, which are subject to tax in Ireland.

Managing Tax Risks

Given the scale of our business and the number of different tax obligations that we have, risks will inevitably arise from time to time in relation to the interpretation of tax law and nature of our tax profile. The Vision Express tax team proactively seeks to identify, evaluate, manage and monitor these risks and keeps both Vision Express senior management and GrandVision’s Group Tax team informed as required.

Where there is uncertainty surrounding the interpretation of tax laws, we will seek second opinions from external tax advisers, having first established our own understanding of the position, and/or seek to resolve the uncertainty by dialogue with the tax authorities.

Attitude towards tax risk

In making any business decisions that may have tax implications, as with any other business decisions, we will consider reputational and corporate social responsibility aspects of those decisions, as well as purely financial considerations.

Our focus is primarily on minimising tax risks to the business, rather than on seeking tax benefits, and thus, consistent with the approach of GrandVision, we have a low threshold of tolerance of tax risk.

Our approach to Tax planning

In considering how best to operate our business, implementing business changes and undertaking transactions such as acquisitions, we will always have regard to a number of different considerations, one of which will be tax. However any tax planning would only be undertaken if it had commercial and economic substance and would have regard to any potential impact on Vision Express’ reputation, brand, corporate and social responsibilities and future working relationships with HMRC.

We do not undertake tax planning that is contrived or artificial.

Working with HMRC

We maintain a transparent and constructive working relationship with HMRC, and we seek to work with them on a real time basis, where appropriate.

If Vision Express undertakes any significant business changes, such as restructurings or acquisitions, we proactively discuss these with HMRC to explain any impact on our business and its tax affairs.

When submitting tax computations and returns to HMRC, Vision Express discloses all relevant facts and identifies transactions or issues where it considers that there is potential for the tax treatment to be uncertain.

Any inadvertent errors in submissions made to HMRC are fully disclosed as soon as reasonably practicable after they are identified, whether they are in Vision Express’ favour or otherwise.