Tax Strategy

CINCO TOPCO TAX STRATEGY
This document, as approved by the Board of Cinco Topco Limited sets out the Group’s
approach to conducting its tax affairs and dealing with tax risk for the financial year ending
27 June 2026.
Scope
This strategy applies to the group of companies headed by Cinco Topco Limited in
accordance with paragraph 19 of Schedule 19 to the Finance Act 2016. A list of the entities to
which it applies is set out below. In this strategy, references to ‘Bright Blue Foods’ ‘BBF’,
‘Group’ or ‘sub-group’ are intended to apply to all these entities. The strategy is being
published in accordance with paragraph 16(4) of the Schedule.
This strategy applies from the date of publication until it is superseded. References to ‘UK
Taxation’ are to the taxes and duties set out in paragraph 15(1) of the Schedule which include
Income Tax, Corporation Tax, PAYE, NIC, VAT, Insurance Premium Tax, and Stamp Duty
Land Tax. References to ‘tax’, ‘taxes’ or ‘taxation’ are to UK taxation and to all
corresponding worldwide taxes and similar duties in respect of which the UK Group has legal
responsibilities.
Aim
Cinco Topco Limited is committed to full compliance with all statutory obligations and full
disclosure to relevant tax authorities.
Risk Management
Cinco Topco Limited recognises that filing tax returns with the authorities and payment of
associated liabilities is one of its key responsibilities. Ultimate responsibility for the Group’s
tax strategy and compliance rests with the Board. The Board refers collectively to the Board
of Directors of each of the entities listed below.
Oversight of the Groups’ taxation obligations is assigned to the Chief Financial Officer,
whose responsibility is to appraise the Board of Directors of key tax events and is supported
by an appropriately qualified and experienced Financial Control team.
The Group operates a system of tax risk assessment and controls as a component of the
overall internal control framework applicable to the group’s financial reporting system.
The Group seeks to maintain a low level of tax risk arising from its operations as far as is
reasonably practicable by ensuring that reasonable care is applied in relation to all processes
which could materially affect its compliance with its tax obligations.
Where there is significant uncertainty or complexity in relation to a risk, external advice is
sought when appropriate.
Attitude towards tax planning and level of risk
In structuring our commercial activities, the Group will consider the tax laws of the countries
in which it operates. Any structuring that is undertaken will have commercial and economic
substance and utilise available tax incentives, reliefs and exemptions in line with, and in the
spirit of, tax legislation. The Group will not put in place any arrangements that are contrived
or artificial.
The Group manages risks to ensure compliance with legal requirements in a manner which
ensures paying the right amount of tax in the right place at the right time.
The level of risk which the Group accepts in relation to UK taxation is consistent with its
overall objective of achieving certainty in its tax affairs. At all times, the Group seeks to
comply fully with its regulatory and other obligations and to act in a way which upholds its
reputation as a responsible corporate citizen. In relation to any specific issue or transaction,
the Board is ultimately responsible for identifying the risks, including tax risks, which need to
be addressed and for determining what actions should be taken to manage those risks, having
regard to the materiality of the amounts and obligations in question.
Relationship with HMRC
The Group seeks to have a transparent and constructive relationship with HMRC. The
Group’s interactions with HMRC are conducted in an open, collaborative and professional
manner.
The Group ensures that HMRC is kept aware of significant transactions and changes in the
business and seeks to discuss any tax issues arising at an early stage. When submitting tax
computations and returns to HMRC, the Group discloses all relevant facts and identifies any
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.
List of entities covered by this Tax Strategy
 Cinco Topco Limited
 Cinco Bidco Limited
 BBF Holdings Limited
 Bright Blue Foods Limited
 Sargents Bakeries Limited