This document sets out the approach to tax of Vision Express Limited and its UK subsidiary undertakings (“Vision Express”) and relates to the year ended 31 December 2023. In making this strategy document available, Vision Express is fulfilling its responsibilities under Schedule 19, paragraph 19(2) 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:
- Be compliant at all times, making all necessary tax returns and tax payments.
- Implement appropriate processes to ensure we meet all of our tax obligations and to identify and address any tax risks that may arise.
- Consider the tax impact in significant or complex business decisions, for example acquisitions or business changes.
- Seek to utilise available tax reliefs where available in a manner which is consistent with the government’s policy objectives.
- Operate in an environment where we consider tax in the context of our reputation and brand.
We are a wholly owned subsidiary of EssilorLuxottica S.A. based in France, and adhere to the principles and philosophy of that company. As regards tax, these principles are set out in the Essilor Luxottica Tax Control Framework.
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, and the company operating the Jersey Vision Express store, which is subject to tax in Jersey.
Ownership of risk and governance of UK tax resides with Vision Express’ Chief Financial Officer (CFO) who is also the Senior Accounting Office of the business. Vision Express has an experienced and suitably qualified tax team who are responsible for the day-to-day management of tax matters, reporting directly into the CFO.
Given the scale of our business, the number of different tax obligations that we have and the complexity of the tax environment, 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 EssilorLuxottica’s Group Tax team informed as required.
Where there is material 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.
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 EssilorLuxottica, we have a low threshold of tolerance of tax risk.
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.
We maintain a transparent and constructive working relationship with HMRC, and we seek to work with them on an ongoing and collaborative basis, including through the annual Business Risk Review process.
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.