Tax Strategy

This document, approved by the board of Mitchell & Ness International Limited, sets out Mitchell & Ness International Limited’s approach to conducting its tax affairs and dealing with tax risks. Publication of this tax strategy is regarded as complying with the duty under paragraph 16 (2) of schedule 19 of Finance Act 2016 in respect of the financial year ending December 2024.

Mitchell & Ness International Limited is committed to:

• Following all applicable laws and regulations relating to its tax activities.
• Maintaining an open and honest relationship with the tax authorities based on collaboration and integrity.
• Applying diligence and care in our management of the processes and procedures by which all tax related activities are undertaken, and ensuring that our tax governance is appropriate.

Governance in relation to UK taxation

Ultimate responsibility for Mitchell & Ness International Limited’s tax strategy and compliance rests with the board of Mitchell & Ness International Limited. The Vice President of Tax (‘VP Tax’) of Fanatics Holdings, Inc (the holding company of the Group) has executive responsibility for tax matters.

Day-to-day management of Mitchell & Ness International Limited’s tax affairs is delegated to the VP of International of Mitchell & Ness International, with outsourced support from third party accountancy firms where required.

Risk management

Managing Mitchell & Ness International Limited’s tax affairs is a complex process across many functional areas of the business. As with any complex process, there may be risks of error or omission within those processes (tax risks) which may result in the incorrect application of tax rules or calculation of tax returns.  Mitchell & Ness International Limited seeks to mitigate and reduce the level of tax risks arising from its operations as far as is reasonably practicable. Reasonable care and attention is applied in relation to all processes that may materially affect its compliance with its tax obligations.

Identified tax risks are assessed on a case by case basis, allowing Mitchell & Ness International Limited to assess and conclude how each individual risk should be managed.  Where there is significant uncertainty in relation to a tax risk, external advice may be sought from reputable accounting and legal professionals to support Mitchell & Ness International Limited’s decision-making process.

When reviewing the tax risks associated with a specific decision or action, Mitchell & Ness International Limited ensures that the following are considered:

• The legal and fiduciary duties of directors and employees.
• All legal, regulatory or compliance requirements of Mitchell & Ness International Limited
• The requirements of any related internal policies or procedures.
• Any impact to stakeholders of Mitchell & Ness International Limited, including corporate and external stakeholders.

We believe this approach is in keeping with the Group’s desire to keep tax risk low.

Tax planning

Mitchell & Ness International Limited has clearly defined lines of responsibility for its tax affairs with decisions being taken at an appropriate level.

Mitchell & Ness International Limited does not enter into artificial tax planning arrangements.

Mitchell & Ness International Limited’s tax planning aims to support the commercial needs of the business by ensuring that the companies’ affairs are carried out in the most tax efficient manner whilst remaining compliant with all relevant laws. The Finance function, containing individuals with recognised accounting qualifications, is therefore involved in commercial decision-making processes and provides appropriate input into business proposals to ensure a clear understanding of the tax consequences of any decisions made. This approach to tax planning is consistent with that taken by the overall Group.

In complex cases where the tax position is unclear, or Mitchell & Ness International Limited does not feel it has the necessary expert knowledge to assess the tax consequences adequately, external advice may be sought from reputable accounting and legal professionals as appropriate.

How Mitchell & Ness International Limited works with HMRC

Mitchell & Ness International Limited is committed to the principles of honesty, openness and transparency in its approach to dealing with HMRC and commits to:

• Make fair, accurate and timely disclosure in correspondence and returns, and respond promptly to queries and information requests.
• Seek to resolve issues with HMRC in a timely manner.
• Be open and transparent about decision-making, governance and tax planning.
• Not enter into transactions that have the main purpose of gaining a tax advantage.
• Ensure all interactions with HMRC are conducted in an open, collaborative, and professional manner. The financial professionals who deal with tax planning and compliance are expected to adopt this approach and are expected to maintain the high ethical standards demanded by the professional bodies to which they belong.

Published 11/12/2024