Tax risk and planning

Our decisions regarding how we conduct the All England Club group’s business have regard to commercial and economic substance. We will not enter or implement transactions in a manner which is contrived, high risk, artificial, result in significant levels of uncertainty or are abusive for tax purposes.

We will claim any allowable reliefs or deductions, including entitlement to reliefs pursuant to double tax treaties, and we will seek to maintain taxation arrangements agreed with HMRC which benefit The Championships and tennis in the UK. These include arrangements whereby:

the financial surplus arising from the operations of The Championships is divided under arrangements whereby the All England Club group receives and pays corporation tax on 10% of the surplus and the remaining 90% of the surplus is distributed to LTA Limited (or one of its group companies as it nominates) and is included in the LTA’s tax calculations and payments (after deduction of allowable costs).
in accordance with other long standing arrangements disclosed to and agreed with HMRC the proceeds from debentures issued by The All England Lawn Tennis Ground plc (an All England Club group company) are treated as capital funding subject to VAT but not subject to corporation tax.

In light of the size and complexity of our business, risks may arise in relation to interpreting complex tax law. We have a low risk appetite for tax risks. We manage these risks by identifying and assessing them internally, seeking professional advice where appropriate, engagement with the Finance & Audit Committee and Board of Directors on any potential significant risks and by seeking HMRC’s views and agreement in relation to any areas of particular uncertainty or change of historically agreed taxation treatment. We continue to consider our tax treatment in accordance with new legislation as it is issued.